Federal Deposit Insurance Corporation v. Jones et al

Filing 59

PROTECTIVE ORDER Granting 58 Stipulated Protective Order. Signed by Magistrate Judge George Foley, Jr on 03/10/2014. (Copies have been distributed pursuant to the NEF - AC)

MORRIS LAW GROUP
Robert McCoy, No. 9121
Email: [e-mail]
Joni A. Jamison, No. 11614
Email: [e-mail]
900 Bank of America Plaza
300 South Fourth Street
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
ATER WYNNE LLP
Frank V. Langfitt III (pro hac vice)
Email: [e-mail]
James B. Davidson (pro hac vice)
Email: [e-mail]
Jeff M. Peterson (pro hac vice)
Email: [e-mail]
1331 NW Lovejoy Street, Suite 900
Portland, Oregon 97209
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff Federal Deposit
Insurance Corporation as Receiver for
Security Savings Bank
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
FEDERAL DEPOSIT
INSURANCE CORPORATION
AS RECEIVER FOR SECURITY
SAVINGS BANK,
Plaintiff,
vs.
KELLY JONES, STEPHEN
DERVENIS, and THOMAS
PROCOPIO,
Defendants.
______________________________

) Case No. 2:13-cv-00168-JAD-GWF
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)
)
) STIPULATED PROTECTIVE
) ORDER
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)

This Stipulated Protective Order ("SPO") is made by and
between the Federal Deposit Insurance Corporation as Receiver for
Security Savings Bank, Henderson, Nevada ("FDIC-R"), and the former
officers of Security Savings Bank listed on Attachment A hereto
("Defendants"). The FDIC-R and the Defendants are referred to
individually as a "Party" or together as the "Parties."
RECITALS
1.

On February 27, 2009, Security Savings Bank ("Bank" or

"SSB"), Henderson, Nevada was closed by the Nevada Department of
Business and Industry, Financial Institutions Division ("NFID") and the
FDIC was appointed as Receiver. At that time, the FDIC-R succeeded to all
the rights, titles, and privileges of the Bank and its depositors, account
holders, other creditors, and stockholders. 12 U.S.C. 1821(d)(2)(A)(i).
2.

On January 31, 2013, the FDIC-R filed this action in the

United States District Court for the District of Nevada, Civil Action
Number 2:13-cv-00168-JAD-GWF (the "Action"), against the Defendants
seeking damages in excess of $13 million related to seven loans (the "Loan
Transactions"), in which SSB purchased a participation interest.
3.

The Defendants are insured under a Policy issued by

Travelers (the "Policy").
4.

Prior to the commencement of this action, the FDIC-R and

Defendants entered into a Confidentiality and Non-Disclosure Agreement,
executed on various dates in April, 2012 ("Confidentiality Agreement").
This Order does not change or alter the Parties' Confidentiality Agreement;
provided, however, that any documents produced by the FDIC-R or
Defendants in this litigation after May 1, 2013, shall be subject to the terms
and conditions of this Order rather than the Confidentiality Agreement,
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even if such documents had been provided pursuant to the Confidentiality
Agreement.
AGREEMENT
1.

Purpose. This Stipulated Protective Order is entered into

for the purpose of facilitating the exchange of confidential materials in
discovery and making other disclosures, either voluntary or as otherwise
required by the Federal Rules of Civil Procedure or the local rules of this
Court, while simultaneously maintaining the confidential nature of the
documents and information provided to them in connection with this
litigation. This SPO is necessary because some documents exchanged
hereunder contain information protected from disclosure by law, including
private and protected financial information about consumers (such as
protected by the Gramm-Leach-Bliley Act (Pub. L 106-102)), confidential
regulatory information, or commercially sensitive information, disclosure
of which could result in violation of law, or harm to individual consumers
or the Parties.
2.

Definition of Confidential Material. For purposes of this

SPO, "Confidential Material" shall mean certain documents, records, and
information composed or stored in written, electronic, digital, or any other
medium, provided by any Party pursuant to this SPO, and to any
information identifying any names, addresses, account information,
personal information (such as social security number, date of birth, and
any other personal identification information) recognized by law as, or
required to be maintained as, confidential, including, without limitation,
the following:
(a)

Regulatory. Confidential Material related in any

way to the regulation or supervision of the Bank, in whatever form,
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whether preliminary or final, including reports of examination or
inspection, regulatory correspondence, reports, orders, memoranda, or
agreements by, from or with the FDIC in its corporate capacity, the
Nevada Department of Business and Industry, Division of Financial
Institutions ("NFID"), the Federal Reserve Board ("FRB"), or any other
federal or state regulatory authority, and any documents containing
confidential information obtained from any documents and records related
to the supervision or regulation of the Bank. The Parties understand and
agree that the release of such regulatory information may require approval
from independent government agencies, and that no regulatory
documents, however obtained, will be disclosed to third parties not
covered by this Confidentiality Order absent such authority's approval or
an Order of the Court.
(b)

Statutory. Confidential Material includes

documents that are confidential pursuant to the Freedom of Information
Act, 5 U.S.C. § 552 ("FOIA"), 12 C.F.R. § 309.5, the FDIC-R's regulations
governing the disclosure of information, the laws of the State of Nevada, or
any other applicable federal or state laws.
...
...
(c)

Bank and Bank Customers. Confidential Material

related to the Bank, its customers, any trading company involved in
placing orders for commodities futures or options, or any other entity,
including: Automated Clearing House items or transactions, chargebacks,
merchant processing, bank account information, signature cards, bank
statements, general ledger entries, deposit or reserve information,
commodity trading statements, loans and lending transactions, loan
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applications, financial statements and credit reports, business and personal
state and federal income tax forms, correspondence, and related loan
documentation relating to any extension of credit or loan to any borrower.
Examples of "Confidential Material," without limitation, include
documents containing a customer's account number, credit card number,
personal identification number, account balance, information relating to a
deposit account, loan, or borrower relationship and loan application
materials, and documents or information that contain the customer's name,
address, social security number, date of birth or other similar identifying
information.
(d)

Receivership. Confidential Material related to the

receivership of the Bank, including any information on loss or estimates of
such loss on the Bank's assets not publicly available.
(e)

Trade Secret/Proprietary Information. Documents

and information that the Defendants reasonably believe constitute, reflect,
or disclose trade secrets, proprietary data or commercially sensitive
information of the Defendants.
Notwithstanding the foregoing paragraphs (a) - (e), no Party is
estopped or in any way prevented from later challenging the
confidentiality designation of any document.
3.

Confidential Designation and Treatment of Confidential

Material. Confidential Material to be produced by any Party to this
Agreement shall be designated by stamping them with the legend
"Confidential." The failure to designate any documents with such legend
shall not constitute a waiver by the producing Party of the right to assert
that such documents contain protected Confidential Material. In the event
that any Party inadvertently produces confidential documents or
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information without designating the documents or information as
Confidential Material, and if the producing Party subsequently notifies the
receiving Party and their counsel that the documents or information should
have been designated Confidential Material, the Parties agree to treat any
such subsequently identified documents or information as duly designated
Confidential Material and subject to this Agreement. Absent the
"Confidential" designation or the subsequent notification referenced above,
a receiving Party shall have no obligation to treat received material as
Confidential Material.
The Parties specifically reserve the right to disagree with and
contest any such designation of documents or information as Confidential
Material. In the event there is a dispute over whether a particular
document or set of documents is Confidential Material, the
receiving/objecting Party may raise that issue with the Court and shall
maintain its copy(ies) of the challenged documents in confidence unless
and until a ruling is issued by the Court. To the extent that a Party's
confidential designation of any document or material is challenged, it shall
be the designating Party's burden to prove why such document or material
meets the definition of Confidential Material.
4.

Challenge of Confidentiality Designation. A Party shall

not be obligated to challenge the propriety of a designation of
confidentiality at the time made, and a failure to do so shall not preclude a
subsequent challenge thereto. In the event that any Party disagrees at any
stage of these proceedings with the confidentiality designation by the
producing Party, the Parties shall first try to dispose of such dispute in
good faith on an informal basis. If after 15 days the dispute cannot be
resolved, the Party objecting to the designation may, at any time thereafter,
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seek appropriate relief from the Court in which this Action is pending. The
challenged designation shall be maintained and shall remain in full force
and effect pending the Court's determination on the challenged
designation.
5.

Non-disclosure of Confidential Material. All

Confidential Material provided pursuant to this SPO is provided solely and
exclusively for purposes of litigating this Action. Absent further written
agreement between the Parties or further order of this Court, all such
materials shall be maintained confidential pursuant to this SPO and shall
not be disclosed, discussed, or in any way divulged to any person for any
other purpose, except as permitted under this SPO. Provided, however,
that the exchange of Confidential Material between the FDIC as Receiver
for the Bank ("FDIC-R") and the FDIC acting in any of its various other
capacities shall not constitute disclosure for purposes of this Order. Any
such Confidential Material transmitted among various capacities of the
FDIC shall remain subject to this Order and its prohibition on further
disclosure.
6.

Exceptions to Non-Disclosure. The Parties agree that the

Confidential Material shall be used only to investigate, analyze, litigate,
and resolve this Action. The Parties may disclose Confidential Material
received pursuant to this SPO to the following persons or entities,
identified in paragraphs 7 and 8, below, provided that each person or
entity required to do so has complied with paragraph 9 below.
7.

Exceptions to Non-disclosure: Defendants and Travelers.

Upon Travelers' execution of the SPO in the form of Attachment C,
Travelers may receive Confidential Material produced by FDIC-R, and
subject to Paragraph 9 below, the Defendants and Travelers may disclose
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Confidential Material received pursuant to this SPO to the following
persons or entities:
(a)

The Defendants and their counsel who have signed

(b)

Travelers' outside counsel who signed this SPO and

this SPO;
Travelers personnel (including, but not limited to, its Board of Directors,
in-house attorneys, investigators, senior executives) conducting, assisting,
monitoring, reviewing, or making determinations with regard or related to
the Action;
(c)

Outside counsel (together with any employees of

counsel), who have not otherwise signed this SPO, engaged by the
Defendants and/or Travelers to assist or participate in the above matters;
(d)

Vendors, experts, consultants, mediators, and

arbitrators engaged by the Defendants and/or Travelers and/or their
respective counsel to assist or participate in the above matters;
(e)

Reinsurers, auditors or other entities to which

Travelers may be required to respond or report in the ordinary course of
business regarding the subject matter of the Action, but only so long as
such persons or entities are already subject to substantially similar
confidentiality obligations;
(f)

Regulators to which Travelers may be required to

respond or report in the ordinary course of business regarding the subject
matter of the Action;
(g)

Court officials involved in this Action including

court reporters, certified translators or interpreters, and other Court
personnel as are necessarily incident to the conduct of discovery, the
preparation for the trial or the trial itself;
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(h)

Other Bank officers, directors, employees,

independent contractors, or outside accountants or auditors who
performed work for the Bank; and
(i)

Non-party witnesses who have executed

Attachment B, provided however, if in the course of deposition or trial
testimony of said witness the witness has declined to execute Attachment
B, the examination of said witness may proceed and the witness may be
shown Confidential Material, but the witness shall not be given a copy of
said material. Provided, however, that as to such deposition witnesses that
decline to execute Attachment B, any Confidential Material to be used as
exhibits shall be attached in a Confidential Appendix of exhibits, separate
from the balance of the exhibits.
8.

Exceptions to Non-disclosure: FDIC-R. Notwithstanding

anything to the contrary herein, but subject to Paragraph 9 below, the
FDIC-R may disclose Confidential Material received pursuant to this SPO
to the following persons or entities:
(a)

FDIC-R personnel (including, but not limited to, its

Chairman, Board of Directors, attorneys, investigators and senior
executives) conducting, assisting, monitoring, reviewing, or making
determinations with regard or related to the Action, and FDIC-R's counsel
who have signed this SPO;
(b)

Outside counsel (together with any employees of

counsel) who have not otherwise signed this SPO, engaged by the FDIC-R
to assist or participate in the above matters;
(c)

Vendors, experts, consultants, mediators, and

arbitrators engaged by the FDIC-R or its counsel to assist or participate in
the above matters;
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(d)

Auditors or examiners required or authorized by

law to review materials that may include Confidential Material;
(e)

Persons to whom the information is required to be

made available under the FOIA or the FDIC-R's FOIA regulations, 12 C.F.R.
§ 309.5, upon receipt of a proper FOIA request for such information;
(f)

Court officials involved in this Action including

court reporters, certified translators or interpreters, and other Court
personnel as are necessarily incident to the conduct of discovery, the
preparation for the trial or the trial itself;
(g)

Other Bank officers, directors, employees,

independent contractors, or outside accountants or auditors who
performed work for the Bank;
(h)

Non-party witnesses who have executed

Attachment B, provided however, if in the course of examining said
witness the witness has declined to execute Attachment B, the examination
of said witness may proceed and the witness may be shown Confidential
Material, but the witness shall not be given a copy of said material.
Provided, however, that as to such witnesses that decline to execute
Attachment B, any Confidential Material to be used as exhibits shall be
attached in a Confidential Appendix of exhibits, separate from the balance
of the exhibits; and
(i)

Any officer, director, or employee of NFID.

If and to the extent either party believes that Confidential
Material should be disclosed to any person not specifically covered within
the foregoing lists, or a person to whom Confidential Receivership
Materials may not be disclosed pursuant to paragraph 2(d) above, such
Party shall request that the other Party consent to the disclosure of
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Confidential Material to such proposed recipient. The other Party shall
review the request in good faith and respond to it within five (5) business
days. Neither Party waives its right to seek permission from the Court to
disclose to the proposed person in the event that the terms of the consent
cannot be agreed upon. In no event shall any Confidential Material be
disclosed to any person, by consent or by identification in the foregoing
lists, without such person first having executed the appropriate
acknowledgements and agreements required herein.
9.

Confidentiality Order Certificate. Confidential Material

may only be disclosed to persons or entities identified in subparagraphs
7(c) - (d) and 8(b)-(c) after that person or entity, through an authorized
representative, agrees to be bound by this Agreement and signs a written
Agreement to Maintain Confidentiality in the form attached as Attachment
B unless such persons or entities dealt with the Confidential Material in the
ordinary course of their duties prior to February 27, 2009. The signature of
any representative with authority to sign on behalf of an entity is sufficient
to bind the entity, and all persons employed or otherwise retained by the
person or entity. The Parties shall keep all of their respective Agreements
to Maintain Confidentiality containing original signatures.
10.

Demands by Others for Confidential Materials. If any

other person or entity demands by subpoena, other judicial process, or by
operation of law, production by a Party of any Confidential Material
produced to it by another Party, the Party receiving such demand shall
promptly notify the producing Party of such demand. At its option, the
producing Party may elect to challenge the demand and assert any
applicable protections. The burden and expense of such challenge shall be
borne solely by the producing Party. The producing Party shall notify the
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recipient Party and issuing court or tribunal of its challenge within such
time as required by law, the subpoena, or other judicial process. The
burden of proving that Confidential Material is entitled to protection from
disclosure shall lie with the Party making the claim. When such a
challenge is made, the Party who received the demand shall not produce
any Confidential Material in the absence of consent by the producing Party
or an order by the issuing court or tribunal compelling production.
Nothing in this provision or this SPO shall be interpreted as requiring any
Party to violate any applicable law.
11.

No Waiver of Objections to Use; Filing Under Seal. The

Parties hereto shall not contend or assert that a Party's production of
Confidential Material pursuant to this SPO in any way acts as a waiver of
any privilege, work product doctrine, or discovery or evidentiary
objections by the producing Party, or otherwise entitles the receiving Party
to obtain or use Confidential Material in a manner contrary to this SPO. In
the event a Party wishes to file Confidential Material with the Court, the
Party wishing to file the Confidential Material shall request that it be filed
under seal and remain under seal until such time as the Court orders
otherwise, following the Procedure for Filings Under Seal contained under
the Local Rules of Court. Provided however, if the clerk declines to file
said documents under seal, the parties may do so with redactions as
required under the Local Rules of Court.
12.

Reservation of Rights. Nothing in this SPO confers upon

the Parties any further right of access to documents or information not
provided by the other Parties. With respect to Confidential Material thus
produced, each Party reserves its rights under this SPO, and otherwise
under law.
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13.

Return of Documents. Upon final resolution of the Action

through the claim process, settlement, or entry of a final, non-appealable
judgment governing the rights and obligations of the FDIC-R and the
Defendants with respect to the Action, the persons and entities identified in
subparagraphs 7(a)-(d) or 8(a)-(c) may retain copies of any Confidential
Material produced to them as reasonably necessary to comply with future
requests for review by reinsurers, auditors and regulators, or as necessary
to exercise or enforce any subrogation rights, or as necessary to meet other
business requirements. When such retention is no longer needed, such
persons and entities shall return the retained documents or destroy those
documents in accordance with their standard record destruction
procedures, subject to any applicable litigation hold or any other document
or information hold imposed by any governmental body or court order.
Any person or entity retaining such Confidential Material shall maintain its
confidentiality in accordance with this Agreement until such documents
are returned or destroyed. This paragraph does not apply to any
documents or information ordered produced by a court without the
limitations set forth in this Agreement. The Parties further agree that all
documents generated by them that summarize or otherwise include
Confidential Material are governed by this SPO. To the extent any Party
retains any Confidential Material pursuant to a separate written agreement,
the terms of this SPO will continue to govern. Upon request by the
producing Party, the receiving Party will provide appropriate certificates
with respect to disposition of the Confidential Materials.
14.

Remedies. To enforce rights under this SPO, or in the

event of an alleged violation of this SPO, the Parties shall first seek to
resolve the alleged violation through prompt and reasonable discussion. In
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the event such efforts fail to promptly resolve the alleged violation, the
Parties reserve the right to initiate litigation in the Court in the Action for,
inter alia, money damages, injunctive relief, or any other relief as
appropriate.
15.

No Waiver of Privileges; Inadvertent Production

Procedure. The Parties do not waive any privilege, including any attorneyclient privilege, work product doctrine, or any other applicable privilege
they might have with respect to any of the documents and information
produced, nor do the Parties waive the right to challenge any assertion of
privilege by entering into this SPO. With respect to the FDIC in any of its
capacities, these privileges include, but are not limited to, any privilege
that the Bank may have had or any federal or state regulatory agency may
hold. The Parties' production of Confidential Material is not intended to,
and shall not, waive or diminish in any way the confidentiality of such
material or its continued protection under the attorney-client privilege,
work product doctrine, or any applicable privilege as to any other third
party.
Furthermore, in the event that a Party inadvertently produces
attorney-client privileged documents or information, and if the Party
subsequently notifies the receiving Party that the privileged documents or
information should not have been produced, the receiving Party agrees to
immediately return the originals and all copies of the inadvertently
produced privileged documents and information. Nothing herein shall
prevent the FDIC-R from using any Confidential Material that it produces
to the Defendants in any of its capacities for any lawful purposes.

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In addition, with regard to privileged and/or otherwise
protected documents, Federal Rule of Evidence 502 is hereby expressly
incorporated into this SPO.
16.

Modification; Waiver. This SPO is based on the

stipulation between the Parties regarding the subject matter hereof and any
prior oral or written statements concerning same are merged herein for all
purposes and shall be of no force and effect. A modification or waiver of
any of the terms of this SPO must be in writing and signed by all Parties, or
approved by the Court after motion filed by a Party. The captions heading
the paragraphs of this SPO are inserted for convenience only and shall not
affect the meaning or interpretation of the provisions hereof.
17.

Binding Effect; Assignment. The SPO shall be binding

upon and inure to the benefit of the Parties hereto, their affiliates, their
representatives, and the Parties' respective successors or assigns. No Party
may assign any right or delegate any duty under this SPO other than to an
affiliate without the other Party's prior written consent.
18.

Notice. All notices required to be given under this SPO

shall be in writing and delivered to the addressees set forth below. Notice
shall be sent by overnight delivery or registered or certified mail, return
receipt requested, and shall be considered delivered upon receipt.
If to the FDIC-R:

Frank V. Langfitt, III, Esq.
Ater Wynne LLP
1331 NW Lovejoy Street, Ste. 900
Portland, Oregon 97209
Robert McCoy, Esq.
Morris Law Group
900 Bank of America Plaza
300 S. Fourth Street
Las Vegas, Nevada 89101
And
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Federal Deposit Insurance Corporation
3501 Fairfax Drive, Room VS-B-7064
Arlington, Virginia 22226-3500
Attn: ___________________
If to the Defendants:

K. Lawson Pedigo
Miller Keffer & Pedigo PLLC
8401 N. Central Expressway, Suite 630
Dallas, Texas 75225
Carleton R. Burch
Anderson, McPharlin & Conners LLP
777 North Rainbow Boulevard, Suite 145
Las Vegas, Nevada 89107

If to Travelers:

19.

Ms. Catherine Powell
Travelers
Pro E&O Claim Unit
385 Washington Street, MC:508F
St. Paul, Minnesota 55102

Power of Execution of Agreement. Each of the signatories

severally represents and warrants that he, she or it, in the capacities recited
herein, has the full power and authority to execute, deliver and perform
this Stipulated Protective Order.
20.

Execution; Facsimile Signatures; Counterparts. This SPO

may be executed as facsimile or scanned and e-mailed originals, and each
copy of this SPO bearing the facsimile transmitted or scanned and e-mailed
signature of a Party's authorized representative shall be deemed an
original. This SPO may be executed in two or more counterparts, each of

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which shall be deemed an original, but all of which together shall
constitute one and the same instrument.
MORRIS LAW GROUP

ANDERSON, McPHARLIM&
CONNERS LLP

By: /s/ Robert McCoy
Robert McCoy, Bar No. 9121
Joni A. Jamison, Bar No. 11614
900 Bank of America Plaza
300 South Fourth Street
Las Vegas, Nevada 89101

By: /s/ Carleton R. Burch
Carleton R. Burch, Bar No. 10527
777 N. Rainbow Boulevard
Suite 145
Las Vegas, NV 89107

ATER WYNNE LLP
Frank V. Langfitt, III (pro hac vice)
Jeff M. Peterson (pro hac vice)
1331 NW Lovejoy Street
Suite 900
Portland, Oregon 97209
Attorneys for Plaintiff Federal
Deposit Insurance Corporation as
Receiver for Security Savings Bank

MILLER KEFFER & PEDIGO PLLC
K. Lawson Pedigo (pro hac vice)
8401 North Central Expressway
Suite 630
Dallas, Texas 75225
Attorneys for Defendants Kelly
Jones, Stephen Dervenis, and
Thomas Procopio

ORDER
IT IS SO ORDERED.
_________________________________________
GEORGE FOLEY, JR.
UNITED STATES DISTRICT COURT JUDGE
United States Magistrate Judge
March 10, 2014
DATED: _________________________________

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ATTACHMENT A
Defendants

Represented by K. LAWSON PEDIGO, ESQ.
and CARLETON R. BURCH, ESQ.

Kelly Jones
Stephen Dervenis
Thomas Procopio

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ATTACHMENT B
AGREEMENT TO MAINTAIN CONFIDENTIALITY
I hereby acknowledge that I have been provided and have read
a copy of that certain Stipulated Protective Order ("SPO") dated _________,
2014, in the action entitled Federal Deposit Insurance Corporation as
Receiver for Security Savings Bank v. Kelly Jones; Stephen Dervenis; and
Thomas Procopio, a copy of which is annexed hereto. I understand that
any Confidential Material within the meaning of the SPO shown to me is
confidential, shall be used by me only as provided in the SPO, and shall not
be disclosed by me unless expressly permitted under the SPO. I agree to
abide by the terms of the Agreement, including its provisions concerning
the return or destruction of such Confidential Material. I acknowledge that
I may be subject to claims for monetary damages and/or injunctive relief
for unauthorized disclosure or use of Confidential Material or if I violate
any obligation of this SPO.
Name: _____________________________ Date: _______________________
(signature)
Name: _____________________________
(printed)
Telephone: __________________
(Business)
Company: __________________________
___________________
(Home)
Address 1: __________________________
Address 2: __________________________
City: _______________________________
State/Zip Code: _____________________

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___________________
(Cell)

ATTACHMENT C
AGREEMENT TO MAINTAIN CONFIDENTIALITY
Travelers has been provided and read a copy of that certain
Stipulated Protective Order ("SPO") dated __________________, 2014, in the
action entitled Federal Deposit Insurance Corporation as Receiver for Security
Savings Bank v. Kelly Jones; Stephen Dervenis; and Thomas Procopio, a copy of
which is annexed hereto. Travelers understands that any Confidential
Material within the meaning of the SPO shown to Travelers is confidential,
shall be used by Travelers only as provided in the SPO, and shall not be
disclosed by Travelers unless expressly permitted under the SPO.
Travelers agrees to abide by the terms of the Agreement, including its
provisions concerning the return or destruction of such Confidential
Material.
TRAVELERS:
By: ________________________________
(signature)

Date: _______________________

Name: _____________________________
(printed)
Telephone: __________________
(Business)
Address 1: __________________________
Address 2: __________________________
City: _______________________________
State/Zip Code: _____________________

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