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Shepard v. Trans Union, LLC

United States District Court, E.D. Michigan, Southern Division

September 27, 2017

ALEIGHCIA SHEPARD, Plaintiff,
v.
TRANS UNION, LLC, et al., Defendants.

         AGREED TO:

          Carl Schwartz (by consent) Attorney for Plaintiff.

          Charity A. Olson (by consent) Attorney for Merchants & Medical Credit Corporation, Inc.

          Tamara E. Fraser Attorney for Defendant Experian Information Solutions, Inc.

          AGREED MUTUAL PROTECTIVE ORDER

          MATTHEW F. LEITMAN UNITED STATES DISTRICT JUDGE

         Plaintiff, Defendant Experian Information Solutions, Inc. and Defendant Merchants & Medical Credit Corporation, Inc. hereby stipulate and agree to the following Protective Order.

         BACKGROUND

         A. 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 and other proprietary information belonging to the Defendants and/or personal income, credit and other confidential information of Plaintiff.

         B. The parties desire to enter into a mutual agreement regarding the confidentiality of this information and governing the production and use of this information.

         NOW THEREFORE, this matter having come before the Court and the Court, being first duly advised, now finds and orders as follows:

         1. Right to Designate Information as "Confidential".

         Counsel for any party (or for a nonparty witness or deponent which shall be included in the term “Designating Party”) may designate as “Confidential” any document, testimony or other discovery material that contains confidential commercial or financial information or trade secret information to which they in good faith believe access should be limited to litigation counsel presently of record for the parties, or subsequently substituted.

         2. Definition of “Confidential” Information.

         The term “Confidential” means information so designated by a Designating Party in writing (or orally if recorded as part of a deposition or court record), whether revealed during a deposition, in a document, in an interrogatory answer, by production of tangible evidence or otherwise.

         3. Definition of ...


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