Lowery v. Wells Fargo, N.A.

          Leif Lowery, Plaintiff, represented by Robert Steven Gimblin, II, Law Office of Steve Gimblin.

          Wendy Lowery, Plaintiff, represented by Robert Steven Gimblin, II, Law Office of Steve Gimblin.

          Wells Fargo, N.A., Defendant, represented by Elizabeth Holt Andrews, Severson & Werson & Thomas N. Abbott, Severson & Werson, P.C..

          Experian Information Solutions, Inc., Defendant, represented by Jennifer Sun, Jones Day, Katherine A. Neben, Jones Day & Kelsey Alissa Israel-Trummel, Jones Day.

          Equifax Information Services, LLC, Defendant, represented by Thomas Patrick Quinn, Jr., Nokes & Quinn.

          STIPULATION AND [PROPOSED] PROTECTIVE ORDER

          EDMUND F. BRENNAN, Magistrate Judge

         IT IS HEREBY STIPULATED by and between Plaintiffs Leif Lowery and Wendy Lowery ("Plaintiffs"), and Defendants Experian Information Solutions, Inc. ("Experian"), Equifax Information Services, LLC ("Equifax"), and Wells Fargo Bank, N.A. ("Wells Fargo") (Experian, Equifax and Wells Fargo are collectively referred to herein as "Defendants"), through their respective attorneys of record, as follows:

         WHEREAS, Fed. R. Civ. Proc. 26(c)(1) requires a showing of good cause for the entry of a protective order by the Court to prevent public disclosure of non-public material such as trade secrets or other confidential research, development, or commercial information;

         WHEREAS, documents and information have been and may be sought, produced or exhibited by and among the parties to this action relating to trade secrets, confidential research, development, technology or other proprietary information belonging to Defendants, and/or personal income, credit and other confidential information of Plaintiffs;

         WHEREAS, an order of this Court is necessary to protect Defendants from annoyance, embarrassment, oppression, or undue burden or expense related to the disclosure of Defendants' confidential, proprietary or private information for purposes other than prosecuting and defending this litigation; and

         WHEREAS, this Order does not confer blanket protection on all disclosures or responses to discovery, and the protection it gives from public disclosure and use extends only to the specific documents and material entitled to confidential treatment under applicable legal principles.

         THEREFORE, an Order of this Court protecting such confidential information shall be and hereby is made by this Court on the following terms:

         1. In accordance with Local Rule 141.1(c), this Order shall govern the use, handling and disclosure of the following categories of confidential documents:

a. Experian Confidential Documents: Policy and Procedure materials; Training materials; Administrative Reports; Dispute Response Logs (or "D/R") Logs; Disclosure Logs; and Transaction Logs (collectively, the "Experian Confidential Documents"). The Experian Confidential Documents are all internal materials created by Experian exclusively for use by its employees, and/or reports generated by Experian's computer system for a specific consumer and in response to the instant lawsuit. These Experian Confidential Documents may only be generated by a very limited number of trained Experian employees, and access is restricted to those with an absolute need to know. The Experian Confidential Documents contain "trade secret or other confidential research, development, or commercial information, " as defined in Fed. R. Civ. Proc. 26(c)(1)(G). Codes appearing throughout the Experian Confidential Documents provide critical information about Experian's computer credit reporting system, which embodies the core of Experian's business. Experian has implemented extensive ...