Alfred Zaklit et al v. Nationstar Mortgage LLC

Filing 23

ORDER APPROVING JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER by Magistrate Judge Kenly Kiya Kato Document 22 (dts)

1 JOHN B. SULLIVAN (State Bar No. 96742)
[e-mail]
2 ERIK KEMP (State Bar No. 246196)
[e-mail]
3 MARY KATE KAMKA (State Bar No. 282911)
[e-mail]
4 SEVERSON & WERSON
A Professional Corporation
5 One Embarcadero Center, Suite 2600
San Francisco, California 94111
6 Telephone: [phone]
Facsimile: [phone]
7
Attorneys for Defendant
8 NATIONSTAR MORTGAGE LLC
9
10

UNITED STATES DISTRICT COURT

11

CENTRAL DISTRICT OF CALIFORNIA

12
13 ALFRED ZAKLIT AND JESSY
ZAKLIT, individually and on behalf of
14 all others similarly situated,
Plaintiffs,

15
16

vs.

Case No. 5:15-CV-02190-CAS-KK
JOINT STIPULATION FOR
ENTRY OF PROTECTIVE ORDER
Action Filed: October 23, 2015

17 NATIONSTAR MORTGAGE LLC and
DOES 1 through 10, inclusive, and each
18 of them,
Defendants.

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80001.0038/7963629.1

JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1

Plaintiffs Alfred Zaklit and Jessy Zaklit (“Plaintiffs”) and Defendant

2 Nationstar Mortgage LLC (“Defendant”) hereby stipulate and move for a Protective
3 Order as provided in Rule 26(c) of the Federal Rules of Civil Procedure. The
4 Parties agree as follows:
5 1.
6

A. PURPOSES AND LIMITATIONS
Disclosure and discovery activity in this action are likely to involve production

7 of confidential, proprietary, or private information for which special protection from
8 public disclosure and from use for any purpose other than prosecuting this litigation
9 may be warranted. Accordingly, the Parties hereby stipulate to and petition the Court
10 to enter the following Stipulated Protective Order. The Parties acknowledge that this
11 Order does not confer blanket protections on all disclosures or responses to discovery
12 and that the protection it affords from public disclosure and use extends only to the
13 limited information or items that are entitled to confidential treatment under the
14 applicable legal principles. The Parties further acknowledge, as set forth in Section
15 12.3, below, that this Stipulated Protective Order does not entitle them to file
16 confidential information under seal; Civil Local Rule 79-5 sets forth the procedures
17 that must be followed and the standards that will be applied when a party seeks
18 permission from the Court to file material under seal.
19

B. GOOD CAUSE STATEMENT

20

Good cause exists for entry of this Stipulated Protective Order because this

21 action could potentially involve proprietary information such as business plans,
22 policies and procedures, contracts, revenue, costs and profit reports, as well as
23 personal financial information, including financial account numbers, and third party
24 borrower contact and loan information. Specifically, Plaintiff has requested that
25 Defendant produce its policies and procedures and training materials, the terms and
26 content of which may not be subject to public disclosure and which Defendant would
27 not share with competitors. Further, documents sought by Plaintiff likely contain
28 personal and/or financial information regarding Defendant’s customers, other than
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JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1 Plaintiff. Likewise, Defendant has requested information from Plaintiff containing
2 personal banking information and other financial information in which Plaintiff has
3 privacy interests.
4

Based on information requested, including that described herein, the Parties

5 anticipate that they will disclose sensitive personal, financial, and/or proprietary
6 information.

Private information of third parties may also be disclosed.

It is

7 important that this information remain protected and not be readily available due to
8 the dangers of identity theft, violating the constitutional privacy rights of third
9 parties, and protection of business competition interests. The unrestricted or
10 unprotected disclosure of such private, financial and/or business information would
11 result in prejudice or harm to the producing party and third parties by revealing their
12 information which could result in identity theft, loss of business and/or violation of
13 federal and state privacy laws.
14

Accordingly, to expedite the flow of information, to facilitate the prompt

15 resolution of disputes over confidentiality of discovery materials, to adequately
16 protect information the Parties are entitled to keep confidential, to ensure that the
17 Parties are permitted reasonable necessary uses of such material in preparation for
18 and in the conduct of trial, to address their handling at the end of the litigation, and
19 serve the ends of justice, a protective order for such information is justified in this
20 matter. It is the intent of the Parties that information will not be designated as
21 confidential for tactical reasons and that nothing be so designated without a good
22 faith belief that it has been maintained in a confidential, non-public manner, and
23 there is good cause why it should not be part of the public record of this case.
24 2.
25

DEFINITIONS
2.1

Action: The pending federal law suit titled Alfred Zaklit, et al. v.

26 Nationstar Mortgage LLC, Central District of California Case No. 5:15-CV-0219027 CAS-KK.
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JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1

2.2

Challenging Party: a Party or Non-Party that challenges the designation

2 of information or items under this Order.
3

2.3

“CONFIDENTIAL” Information or Items: information (regardless of

4 how it is generated, stored or maintained) or tangible things that qualify for
5 protection under Federal Rule of Civil Procedure 26(c) and as specified above in the
6 Good Cause Statement.
7

2.4

Counsel: Outside Counsel of Record and House Counsel (as well as

8 their support staff).
9

2.5

Designating Party: a Party or Non-Party that designates information or

10 items that it produces in disclosures or in responses to discovery as
11 “CONFIDENTIAL.”
12

2.6

Disclosure or Discovery Material: all items or information, regardless

13 of the medium or manner in which it is generated, stored, or maintained (including,
14 among other things, testimony, transcripts, and tangible things), that are produced or
15 generated in disclosures or responses to discovery in this matter.
16

2.7

Expert: a person with specialized knowledge or experience in a matter

17 pertinent to the litigation who has been retained by a Party or its counsel to serve as
18 an expert witness or as a consultant in this Action.
19

2.8

House Counsel: attorneys who are employees of a party to this Action.

20 House Counsel does not include Outside Counsel of Record or any other outside
21 counsel.
22

2.9

Non-Party: any natural person, partnership, corporation, association, or

23 other legal entity not named as a Party to this Action.
24

2.10 Outside Counsel of Record: attorneys who are not employees of a party

25 to this Action but are retained to represent or advise a party to this Action and have
26 appeared in this Action on behalf of that party or are affiliated with a law firm which
27 has appeared on behalf of that party, and includes support staff.
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JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1

2.11 Party: any party to this Action, including all of its officers, directors,

2 employees, consultants, retained experts, and Outside Counsel of Record (and their
3 support staffs).
4

2.12 Producing Party: a Party or Non-Party that produces Disclosure or

5 Discovery Material in this Action.
6

2.13 Professional Vendors: persons or entities that provide litigation support

7 services (e.g., photocopying, videotaping, translating, preparing exhibits or
8 demonstrations, and organizing, storing, or retrieving data in any form or medium)
9 and their employees and subcontractors.
10

2.14 Protected Material:

any Disclosure or Discovery Material that is

11 designated as “CONFIDENTIAL.”
12

2.15 Receiving Party: a Party that receives Disclosure or Discovery Material

13 from a Producing Party.
14 3.
15

SCOPE
The protections conferred by this Stipulation and Order cover not only

16 Protected Material (as defined above), but also (1) any information copied or
17 extracted from Protected Material; (2) all copies, excerpts, summaries, or
18 compilations of Protected Material; and (3) any testimony, conversations, or
19 presentations by Parties or their Counsel that might reveal Protected Material.
20

Any use of Protected Material at trial shall be governed by the orders of the

21 trial judge. This Order does not govern the use of Protected Material at trial.
22 4.
23

DURATION
Even after final disposition of this litigation, the confidentiality obligations

24 imposed by this Order shall remain in effect until a Designating Party agrees
25 otherwise in writing or a court order otherwise directs. Final disposition shall be
26 deemed to be the later of (1) dismissal of all claims and defenses in this action, with
27 or without prejudice; and (2) final judgment herein after the completion and
28 exhaustion of all appeals, rehearings, remands, trials, or reviews of this action,
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JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1 including the time limits for filing any motions or applications for extension of time
2 pursuant to applicable law.
3 5.
4

DESIGNATING PROTECTED MATERIAL
5.1

Exercise of Restraint and Care in Designating Material for Protection.

5 Each Party or Non-Party that designates information or items for protection under
6 this Order must take care to limit any such designation to specific material that
7 qualifies under the appropriate standards. The Designating Party must designate for
8 protection only those parts of material, documents, items, or oral or written
9 communications that qualify – so that other portions of the material, documents,
10 items, or communications for which protection is not warranted are not swept
11 unjustifiably within the ambit of this Order.
12

Mass, indiscriminate, or routinized designations are prohibited. Designations

13 that are shown to be clearly unjustified or that have been made for an improper
14 purpose (e.g., to unnecessarily encumber or retard the case development process or to
15 impose unnecessary expenses and burdens on other parties) may expose the
16 Designating Party to sanctions.
17

If it comes to a Designating Party’s attention that information or items that it

18 designated for protection do not qualify for protection, that Designating Party must
19 promptly notify all other Parties that it is withdrawing the inapplicable designation.
20

5.2

Manner and Timing of Designations. Except as otherwise provided in

21 this Order (see, e.g., second paragraph of section 5.2(a) below), or as otherwise
22 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection
23 under this Order must be clearly so designated before the material is disclosed or
24 produced.
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Designation in conformity with this Order requires:
(a)

for information in documentary form (e.g., paper or electronic

27 documents, but excluding transcripts of depositions or other pretrial or trial
28 proceedings), that the Producing Party affix at a minimum, the legend
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1 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that
2 contains protected material. If only a portion or portions of the material on a page
3 qualifies for protection, the Producing Party also must clearly identify the protected
4 portion(s) (e.g., by making appropriate markings in the margins).
5

A Party or Non-Party that makes original documents available for inspection

6 need not designate them for protection until after the inspecting Party has indicated
7 which documents it would like copied and produced. During the inspection and
8 before the designation, all of the material made available for inspection shall be
9 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents
10 it wants copied and produced, the Producing Party must determine which documents,
11 or portions thereof, qualify for protection under this Order. Then, before producing
12 the specified documents, the Producing Party must affix the “CONFIDENTIAL
13 legend” to each page that contains Protected Material. If only a portion or portions of
14 the material on a page qualifies for protection, the Producing Party also must clearly
15 identify the protected portion(s) (e.g., by making appropriate markings in the
16 margins).
17

(b)

for testimony given in deposition or in other pretrial or trial

18 proceedings, that the Designating Party shall be made either on the record or by
19 written notice to the other party within 30 days of receipt of the transcript. Unless
20 otherwise agreed, depositions shall be treated as “Confidential” during the 30-day
21 period following receipt of the transcript. The deposition of any witness (or any
22 portions of such deposition) that encompasses Confidential information shall be
23 taken only in the presence of persons who are qualified to have access to such
24 information.
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(c) for information produced in some form other than documentary and for

26 any other tangible items, that the Producing Party affix in a prominent place on the
27 exterior of the container or containers in which the information or item is stored the
28 legend “CONFIDENTIAL.” If only a portion or portions of the information or item
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1 warrant protection, the Producing Party, to the extent practicable, shall identify the
2 protected portion(s).
3

5.3

Inadvertent Failures to Designate. If timely corrected, an inadvertent

4 failure to designate qualified information or items does not, standing alone, waive the
5 Designating Party’s right to secure protection under this Order for such material.
6 Upon timely correction of a designation, the Receiving Party must make reasonable
7 efforts to assure that the material is treated in accordance with the provisions of this
8 Order.
9 6.
10

CHALLENGING CONFIDENTIALITY DESIGNATIONS
6.1

Timing of Challenges.

Any Party or Non-Party may challenge a

11 designation of confidentiality at any time that is consistent with the Court’s
12 Scheduling Order.
13

6.2

Meet and Confer.

The Challenging Party shall initiate the dispute

14 resolution process under Local Rule 37.1 et seq.
15

6.3

The burden of persuasion in any such challenge proceeding shall be on

16 the Designating Party. Frivolous challenges, and those made for an improper purpose
17 (e.g., to harass or impose unnecessary expenses and burdens on other parties) may
18 expose the Challenging Party to sanctions. Unless the Designating Party has waived
19 or withdrawn the confidentiality designation, all parties shall continue to afford the
20 material in question the level of protection to which it is entitled under the Producing
21 Party’s designation until the Court rules on the challenge.
22 7.
23

ACCESS TO AND USE OF PROTECTED MATERIAL
7.1

Basic Principles. A Receiving Party may use Protected Material that is

24 disclosed or produced by another Party or by a Non-Party in connection with this
25 case only for prosecuting, defending, or attempting to settle this litigation. Such
26 Protected Material may be disclosed only to the categories of persons and under the
27 conditions described in this Order. When the litigation has been terminated, a
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JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER

1 Receiving Party must comply with the provisions of section 14 below (FINAL
2 DISPOSITION).
3

Protected Material must be stored and maintained by a Receiving Party at a

4 location and in a secure manner that ensures that access is limited to the persons
5 authorized under this Order.
6

7.2

Disclosure of “CONFIDENTIAL” Information or Items. Unless

7 otherwise ordered by the Court or permitted in writing by the Designating Party, a
8 Receiving

Party

may

disclose

any

information

or

item

designated

9 “CONFIDENTIAL” only to:
10

(a) the Receiving Party’s Outside Counsel of Record in this action, as well

11 as employees of said Outside Counsel of Record to whom it is reasonably necessary
12 to disclose the information for this litigation and who have signed the
13 “Acknowledgment and Agreement to Be Bound” that is attached hereto as Exhibit A;
14

(b) the officers, directors, and employees (including House Counsel) of the

15 Receiving Party to whom disclosure is reasonably necessary for this litigation and
16 who have signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
17

(c) Experts (as defined in this Order) of the Receiving Party to whom

18 disclosure is reasonably necessary for this litigation and who have signed the
19 “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(d) the Court and its personnel;

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(e) court reporters and their staff;

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(f) professional jury or trial consultants, mock jurors, and Professional

23 Vendors to whom disclosure is reasonably necessary for this litigation and who have
24 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A);
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(g) the author or recipient of a document containing the information or a

26 custodian or other person who otherwise possessed or knew the information;
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(h) during their depositions, witnesses, and attorneys for witnesses, in the

28 action to whom disclosure is reasonably necessary provided: (1) the deposing party
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1 requests that the witness sign the form attached as Exhibit A hereto; and (2) they will
2 not be permitted to keep any confidential information unless they sign the
3 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise
4 agreed by the Designating Party or ordered by the Court. Pages of transcribed
5 deposition testimony or exhibits to depositions that reveal Protected Material must be
6 separately bound by the court reporter and may not be disclosed to anyone except as
7 permitted under this Stipulated Protective Order;
8

(i) any mediator or settlement officer, and their supporting personnel,

9 mutually agreed upon by any of the parties engaged in settlement discussions.
10 8. PROTECTED MATERIAL SUBPOENAED OR ORDERED PRODUCED IN
11
12

OTHER LITIGATION
If a Party is served with a subpoena or a Court order issued in other litigation

13 that compels disclosure of any information or items designated in this action as
14 “CONFIDENTIAL,” that Party must:
15

(a) promptly notify in writing the Designating Party. Such notification

16 shall include a copy of the subpoena or Court order;
17

(b) promptly notify in writing the party who caused the subpoena or order

18 to issue in the other litigation that some or all of the material covered by the
19 subpoena or order is subject to this Protective Order. Such notification shall include a
20 copy of this Stipulated Protective Order; and
21

(c)

cooperate with respect to all reasonable procedures sought to be

22 pursued by the Designating Party whose Protected Material may be affected.
23

If the Designating Party timely seeks a protective order, the Party served with

24 the subpoena or Court order shall not produce any information designated in this
25 action as “CONFIDENTIAL” before a determination by the Court from which the
26 subpoena or order issued, unless the Party has obtained the Designating Party’s
27 permission. The Designating Party shall bear the burden and expense of seeking
28 protection in that court of its confidential material – and nothing in these provisions
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1 should be construed as authorizing or encouraging a Receiving Party in this action to
2 disobey a lawful directive from another court.
3 9. A NON-PARTY’S PROTECTED MATERIAL SOUGHT TO BE PRODUCED
4

IN THIS LITIGATION

5

(a) The terms of this Order are applicable to information produced by a

6 Non-Party in this action and designated as “CONFIDENTIAL.” Such information
7 produced by Non-Parties in connection with this litigation is protected by the
8 remedies and relief provided by this Order. Nothing in these provisions should be
9 construed as prohibiting a Non-Party from seeking additional protections.
10

(b) In the event that a Party is required, by a valid discovery request, to

11 produce a Non-Party’s confidential information in its possession, and the Party is
12 subject to an agreement with the Non-Party not to produce the Non-Party’s
13 confidential information, then the Party shall:
14

(1) promptly notify in writing the Requesting Party and the Non-Party

15 that some or all of the information requested is subject to a confidentiality agreement
16 with a Non-Party;
17

(2)

promptly provide the Non-Party with a copy of the Stipulated

18 Protective Order in this litigation, the relevant discovery request(s), and a reasonably
19 specific description of the information requested; and
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(3) make the information requested available for inspection by the Non-

21 Party.
22

(c) If the Non-Party fails to object or seek a protective order from this

23 Court within 14 days of receiving the notice and accompanying information, the
24 Receiving Party may produce the Non-Party’s confidential information responsive to
25 the discovery request. If the Non-Party timely seeks a protective order, the Receiving
26 Party shall not produce any information in its possession or control that is subject to
27 the confidentiality agreement with the Non-Party before a determination by the
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1 Court. Absent a Court order to the contrary, the Non-Party shall bear the burden and
2 expense of seeking protection in this Court of its Protected Material.
3 10.UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL
4

If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed

5 Protected Material to any person or in any circumstance not authorized under this
6 Stipulated Protective Order, the Receiving Party must immediately (a) notify in
7 writing the Designating Party of the unauthorized disclosures, (b) use its best efforts
8 to retrieve all unauthorized copies of the Protected Material, (c) inform the person or
9 persons to whom unauthorized disclosures were made of all the terms of this Order,
10 and (d) request such person or persons to execute the “Acknowledgment and
11 Agreement to Be Bound” that is attached hereto as Exhibit A.
12 11.INADVERTENT
13
14

PRODUCTION

OF

PRIVILEGED

OR

OTHERWISE

PROTECTED MATERIAL
When a Producing Party gives notice to Receiving Parties that certain

15 inadvertently produced material is subject to a claim of privilege or other protection,
16 the obligations of the Receiving Parties are those set forth in Federal Rule of Civil
17 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure
18 may be established in an e-discovery order that provides for production without prior
19 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the
20 parties reach an agreement on the effect of disclosure of a communication or
21 information covered by the attorney-client privilege or work product protection, the
22 parties may incorporate their agreement in the stipulated protective order submitted
23 to the court.
24

No disclosure, production, or exchange of documents or information in this

25 case shall constitute a waiver of any applicable attorney-client privilege or of any
26 applicable work product protection in this or any other federal or state proceeding
27 provided that the requirements of Federal Rule of Evidence 502(b), subsections (1),
28 (2), and (3) are met.
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1 12.
2

MISCELLANEOUS
12.1 Right to Further Relief. Nothing in this Order abridges the right of any

3 person to seek its modification by the Court in the future.
4

12.2 Right to Assert Other Objections. By stipulating to the entry of this

5 Protective Order no Party waives any right it otherwise would have to object to
6 disclosing or producing any information or item on any ground not addressed in this
7 Stipulated Protective Order. Similarly, no Party waives any right to object on any
8 ground to use in evidence of any of the material covered by this Protective Order.
9

12.3 Filing Protected Material. A Party that seeks to file under seal any

10 Protected Material must comply with Civil Local Rule 79-5. Protected Material may
11 only be filed under seal pursuant to a court order authorizing the sealing of the
12 specific Protected Material at issue. If a Party’s request to file Protected Material
13 under seal is denied by the court, then the Receiving Party may file the information in
14 the public record unless otherwise instructed by the court.
15 13.
16

FINAL DISPOSITION
After the final disposition of this Action, as defined in paragraph 4, within 60

17 days of a written request by the Designating Party, each Receiving Party must return
18 all Protected Material to the Producing Party or destroy such material. As used in this
19 subdivision, “all Protected Material” includes all copies, abstracts, compilations,
20 summaries, and any other format reproducing or capturing any of the Protected
21 Material. Whether the Protected Material is returned or destroyed, the Receiving
22 Party must submit a written certification to the Producing Party (and, if not the same
23 person or entity, to the Designating Party) by the 60 day deadline that (1) identifies
24 (by category, where appropriate) all the Protected Material that was returned or
25 destroyed and (2) affirms that the Receiving Party has not retained any copies,
26 abstracts, compilations, summaries or any other format reproducing or capturing any
27 of the Protected Material. Notwithstanding this provision, Counsel are entitled to
28 retain an archival copy of all pleadings, motion papers, trial, deposition, and hearing
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1 transcripts, legal memoranda, correspondence, deposition and trial exhibits, expert
2 reports, attorney work product, and consultant and expert work product, even if such
3 materials contain Protected Material. Any such archival copies that contain or
4 constitute Protected Material remain subject to this Protective Order as set forth in
5 Section 4 (DURATION).
6 14.

Any violation of this Order may be punished by any and all appropriate

7 measures including, without limitation, contempt proceedings and/or monetary
8 sanctions.
9 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
10
11 DATED: June 16, 2016
12

SEVERSON & WERSON
A Professional Corporation

13
14

By:

/s/ Erik Kemp
Erik Kemp

15
16

Attorneys for Defendant NATIONSTAR
MORTGAGE LLC

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18
19 DATED: June 16, 2016,

LAW OFFICES OF TODD M. FRIEDMAN,
P.C.

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22
By:

23

/s/ Adrian Bacon
Adrian Bacon

24

Attorneys for Plaintiffs ALFRED ZAKLIT and
JESSY ZAKLIT

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1 FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.
2
3 Dated: June __, 2016
23

_______________________________

4

Honorable Kenly Kiya Kato
United States District Magistrate Judge

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EXHIBIT A

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ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND

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I, _____________________________ [print or type full name], of
_________________ [print or type full address], declare under penalty of perjury that
I have read in its entirety and understand the Stipulated Protective Order that was
issued by the United States District Court for the Central District of California on
________[date] in the case of Alfred Zaklit, et al. v. Nationstar Mortgage LLC,
Central District of California Case No. 5:15-CV-02190-CAS-KK. I agree to comply
with and to be bound by all the terms of this Stipulated Protective Order and I
understand and acknowledge that failure to so comply could expose me to sanctions
and punishment in the nature of contempt. I solemnly promise that I will not disclose
in any manner any information or item that is subject to this Stipulated Protective
Order to any person or entity except in strict compliance with the provisions of this
Order.

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I further agree to submit to the jurisdiction of the United States District Court
for the Central District of California for the purpose of enforcing the terms of this
Stipulated Protective Order, even if such enforcement proceedings occur after
termination of this action.

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I hereby appoint __________________________ [print or type full name] of
_______________________________________ [print or type full address and
telephone number] as my California agent for service of process in connection with
this action or any proceedings related to enforcement of this Stipulated Protective
Order.
Date:

25
26

City and State where sworn and signed: _________________________________

27 Printed name: _______________________________
28 Signature: __________________________________
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ECF Attestation

1
2

I, Erik Kemp, am the ECF user whose identification and password are being

3 used to file this JOINT STIPULATION FOR ENTRY OF PROTECTIVE ORDER.
4 I hereby attest that Adrian Bacon has concurred in this filing.
5 DATED: June 16, 2016
6

SEVERSON & WERSON
A Professional Corporation

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By:

/s/ Erik Kemp
Erik Kemp

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Attorneys for Defendant NATIONSTAR
MORTGAGE LLC

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