Sarkoyan v. Equifax Information Services LLC

Opinion

11 GIA N. MARINA Nevada Bar No. 15276 22 CLARK HILL PLLC 1700 S. Pavilion Center Drive, Suite 500 33 Las Vegas, NV 89135 Telephone: (702) 862-8300 44 Facsimile: (702) 778-9709 E-mail: gmarina@clarkhill.com 55 Attorney for Defendant 66 77 88 UNITED STATES DISTRICT COURT 99 DISTRICT OF NEVADA 1100 VATCHE SARKOYAN, Case No.: 2:24-cv-02316-JCM-BNW

1111 Plaintiff, STIPULATION AND ORDER REGARDING CONFIDENTIAL 1122 v. INFORMATION 1133 EQUIFAX INFORMATION SERVICES, LLC 1144 Defendants. 1155 The following provisions shall govern the exchange of confidential information in this 1166 matter: 1177 1. Counsel for any party may designate any document, information contained in a 1188 document, information revealed in an interrogatory response or information revealed during a 1199 deposition as confidential if counsel determines, in good faith, that such designation is necessary 2200 to protect the interests of the client. Information and documents designated as confidential are to 2211 be stamped “CONFIDENTIAL.” “Confidential” information or documents may be referred to 2222 collectively as “Confidential Information.” If counsel believes in good faith that, despite the 2233 provisions of this Protective Order, there is a substantial risk of identifiable harm if particular 2244 documents it designates as “Confidential” are disclosed, it may designate those particular 2255 documents as “Confidential—Attorneys’ Eyes Only.” 2266 2. Unless ordered by the Court or otherwise provided for herein, the Confidential 2277 Information disclosed will be held and used by the person receiving such information solely for use in connection with the above-captioned action. 1 3. In the event that a party challenges another party’s designation, counsel shall make 2 a good faith effort to resolve the dispute, and in the absence of a resolution, the challenging party 3 may thereafter seek resolution by the Court. Nothing in this Protective Order constitutes an 4 admission by any party that Confidential Information disclosed in this case is relevant or 5 admissible. Each party specifically reserves the right to object to the use or admissibility of all 6 Confidential Information disclosed, in accordance with applicable laws and court rules. 7 4. Information or documents designated as “Confidential” shall not be disclosed to 8 any person except: 9 a. The requesting party and counsel, including in-house counsel; 10 b. Employees of such counsel assigned to and necessary to assist in the litigation; 11 c. The Court (including the clerk, court reporter or stenographer, or other person 12 having access to Confidential Information by virtue of his or her position with the Court) or the 13 jury at trial or as exhibits to motions. 14 d. Subject to the condition set forth in Paragraph 6 below: consultants or experts in 15 the prosecution or defense of the matter, to the extent deemed necessary by counsel; 16 e. Subject to the condition set forth in Paragraph 6 below: any person from who 17 testimony is taken or is to be taken in this action, except that such a person may only be shown 18 Confidential Information during and in preparation for his/her testimony and may not retain the 19 Confidential Information; and 20 5. Prior to disclosing or displaying Confidential Information to any person, counsel 21 shall: 22 a. inform the person of the confidential nature of the information or documents; 23 b. inform the person that this Court has enjoined the use of the information or 24 documents by him/her for any purpose other than this litigation and has enjoined the disclosure of 25 that information or documents to any other person. 26 6. The Confidential Information may be displayed to and discussed with the persons 27 identified in Paragraphs 4(d) and (e) only on condition that prior to any such display each person 1 event that such person refuses to sign an agreement in the form attached as Exhibit A, the party 2 desiring to disclose the Confidential Information may seek appropriate relief from the Court. 3 7. The disclosure of a document or information without designating it as 4 “confidential” shall not constitute a waiver of the right to designate such document or information 5 as Confidential Information provided the material is designated pursuant to the procedures set 6 forth herein no later than fourteen (14) days after that close of discovery or fourteen (14) days 7 after the production of the document or information. If so designated, the document or 8 information shall thenceforth be treated as Confidential Information subject to all of the terms of 9 the Stipulation and Order. 10 8. All information subject to confidential treatment in accordance with the terms of 11 this Stipulation and Order that is filed with the Court, including any pleadings, motions or other 12 papers filed with the Court that includes Confidential Information, shall be filed under seal to the 13 extent permitted by law (including, without limitation any applicable rules of court) and shall be 14 kept under seal until further order of the Court. To the extent that the Court requires any further 15 act by the parties as a precondition to the filing of documents under seal (beyond the submission 16 of this Stipulation and Order Regarding Confidential Information), it shall be the obligation of the 17 producing party of the documents to be filed with the Court to satisfy any such precondition. 18 Where possible, only confidential portions of the filings with the Court shall be filed under seal. 19 9. At the conclusion of the litigation, the Confidential Information and any copies 20 thereof shall be promptly (and in no event no later than thirty (30) days after entry of final 21 judgment no longer subject to further appeal) returned to the producing party or certified as 22 destroyed, except that the parties’ counsel shall be permitted to retain their working files on the 23 condition that such files will remain confidential. 24 The foregoing is without prejudice to the right of any party to apply to the Court for any 25 further Protective Order relating to Confidential Information; or to object to the production of 26 documents or information; or to apply to the Court for an order compelling production of 27 / / 1]} documents or information; or for modification of this order. This Order may be enforced by any 2|| party and any violation of this order may result in the imposition of sanctions by the Court. 3 DATED: April 15, 2025. 4 CLARK HILL PLLC CRAIG K. PERRY & ASSOCIATES By:/s/Gia N. Marina By: /s/ Craig K. Perry 5 Gia N. Marina Craig K. Perry Nevada Bar No. 15276 3450 W. Cheyenne Ave, Suite 400 6 1700 S. Pavilion Center, Ste 400 89032 Suite 500 North Las Vegas, NV 89032 7 Las Vegas, NV 89135 702-228-4777 Tel: (702) 862-8300 Email: cperry@craigperry.com 8 Fax: (702) 778-9709 Attorney for Plaintiff Email: gmarina@clarkhill.com 9 Attorney for Defendant Equifax 10 Information Services LLC

1] || All motions to seal must comply with Local Rule IA 10-5 and Kamakana v. City & Cnty. of 3 Honolulu, 447 F.3d 1172 (9th Cir. 2006). IT IS SO ORDERED.

14 Le Are, 15 UNITED STATES MAGISTRATE JUDGE 16 17 DATED: April 16, 2025 18 19 20 21 22 23 24 25 26 27 28

1 CERTIFICATE OF SERVICE 2 I hereby certify that a true and exact copy of the foregoing has been served this 15th day of 3 April, 2025, via the Court’s CM/ECF system, which will send a notification to all counsel of record.

4 By: /s/Gia N. Marina GIA N. MARINA 5 Nevada Bar No. 15276 6 1700 South Pavilion Center Drive, Suite 500 Las Vegas, Nevada 89135 7 E-mail: gmarina@clarkhill.com Telephone: (702) 862-8300 8 Facsimile: (702) 778-9709 Attorney for Defendant Equifax Information 9 Services LLC 10

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