U.S. Bank, National Association vs Countryside Homeowners Association, et al
Filing
83
PROTECTIVE ORDER pursuant to ECF No. 82 Stipulation. Signed by Magistrate Judge George Foley, Jr on 6/20/2019. (Copies have been distributed pursuant to the NEF - LH)
1
2
3
4
5
6
7
8
9
DARREN T. BRENNER, ESQ.
Nevada Bar No. 8386
SCOTT R. LACHMAN, ESQ.
Nevada Bar No. 12016
AKERMAN LLP
1635 Village Center Circle, Ste. 200
Las Vegas, Nevada 89134
Telephone: (702) 634-5000
Facsimile: (702) 380-8572
Email: darren.brenner@akerman.com
Email: scott.lachman@akerman.com
Attorneys for U.S. Bank, N.A., as Trustee for the
Holders of the CSFB Mortgage Securities Corp.,
Adjustable Rate Mortgage Trust 2005-8,
Adjustable Rate Mortgage-Backed Pass-Through
Certificates Series 2005-8
10
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
11
12
13
14
15
U.S. BANK, NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE HOLDERS OF THE
CSFB MORTGAGE SECURITIES CORP.,
ADJUSTABLE RATE MORTGAGE TRUST
2005-8, ADJUSTABLE RATE MORTGAGE–
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2005-8,
Plaintiff,
16
vs.
17
COUNTRYSIDE
HOMEOWNERS
ASSOCIATION; K K REAL ESTATE
INVESTMENT
FUND,
LLC;
DOE
INDIVIDUALS I-X, inclusive, and ROE
CORPORATIONS I-X, inclusive,
18
19
20
21
22
Defendants.
K K REAL ESTATE INVESTMENT FUND,
LLC
Counter-Claimant,
23
vs.
24
U.S. BANK, NATIONAL ASSOCIATION, AS
TRUSTEE FOR THE HOLDERS OF THE
CSFB MORTGAGE SECURITIES CORP.,
ADJUSTABLE RATE MORTGAGE TRUST
2005-8, ADJUSTABLE RATE MORTGAGE–
BACKED PASS-THROUGH CERTIFICATES,
SERIES 2005-8
25
26
27
28
Counter-Defendant.
49220113;1
Case No.: 2:15-cv-01463-RCJ-GWF
STIPULATED PROTECTIVE ORDER
1
Plaintiff and counter-defendant U.S. Bank National Association, as Trustee for the Holders of
2
the CSFB Mortgage Securities Corp., Adjustable Rate Mortgage Trust 2005-8, Adjustable Rate
3
Mortgage-Backed Pass-Through Certificates, Series 2005-8, defendant Countryside Homeowners
4
Association and, defendant and counter-claimant KK Real Estate Investment Fund, LLC, and Trust
5
stipulate to the following Protective Order:
6
To expedite the flow of discovery, facilitate the prompt resolution of disputes over
7
confidentiality, adequately protect material claimed to be confidential, and ensure protection is
8
afforded only to material so designated, it is, pursuant to the Court's authority under Rule 26(c),
9
ORDERED this Protective Order shall govern the disclosure, handling and disposition of documents
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
10
in this litigation as follows:
11
1.
Application.
12
1.1
This Protective Order shall govern any document, information or other material that is
13
designated as containing "Confidential Information" as defined herein, and is produced in connection
14
with this litigation by any person or entity (the "producing party"), whether in response to a discovery
15
request, subpoena or otherwise, to any other person or entity (the "receiving party") regardless of
16
whether the person or entity producing or receiving such information is a party to this litigation.
17
2.
Definitions.
18
2.1
Confidential Information. "Confidential Information" shall mean and include, without
19
limitation, any non-public information that concerns or relates to the following areas: confidential
20
proprietary information, trade secrets, practices and procedures, personal financial information,
21
commercial, financial, pricing, budgeting, and/or accounting information, information about existing
22
and potential customers, marketing studies, performance projections, business strategies, decisions
23
and/or negotiations, personnel compensation, evaluations and other employment information, and
24
confidential proprietary information about affiliates, parents, subsidiaries and third-parties with whom
25
the parties to this action have or have had business relationships.
2.2
26
Documents. As used herein, the term "documents" includes all writings, records, files,
27
drawings, graphs, charts, photographs, e-mails, video tapes, audio tapes, compact discs, electronic
28
messages, other data compilations from which information can be obtained and other tangible things
49220113;1
1
subject to production under the Federal Rules of Civil Procedure.
2
3.
3
Initial Designation.
3.1
Good Faith Claims. Claims of confidentiality will be made with respect to documents,
4
other tangible things and information that the asserting party has a good faith belief are within the
5
definition set forth in subparagraph 2.1 of this Protective Order. Objections to such claims made
6
pursuant to paragraph 5, below shall also be made only in good faith.
7
3.2
Produced Documents. A party producing documents that it believes constitute or
Order by describing the documents or materials to be treated as confidential in writing, by page or
10
AKERMAN LLP
contain Confidential Information shall state that the material is being produced under this Protective
9
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
8
bates number wherever possible and/or shall produce copies bearing a label that contains or includes
11
language substantially identical to the following:
12
CONFIDENTIAL
13
This label shall be affixed in a manner that does not obliterate or obscure the contents of the
14
copies. If any person or party makes copies of documents designated as containing Confidential
15
Information, the copying person or party shall mark each such copy as containing Confidential
16
Information in the same form as the Confidentiality notice on the original document.
17
A party producing documents that are stored on electronic, magnetic, optical or other non-
18
paper media, such as compact discs, DVD's, video tapes and audio tapes (collectively, "data storage
19
devices") shall designate the data storage device as containing Confidential Information, by affixing a
20
label or stamp to the data storage device in the manner described above at the time copies of such data
21
storage devices are produced. If the receiving party or other persons or entities to whom disclosure is
22
authorized pursuant to subparagraph 7.1 make a copy of any data storage device designated by the
23
producing party as containing Confidential Information, the receiving party or other authorized person
24
shall mark each such copy as containing Confidential Information in the same form as the
25
confidentiality notice on the original data storage device produced. If the receiving party or other
26
authorized person prints out or otherwise makes copies of the documents or information stored on such
27
data storage device, the receiving party or other authorized person shall mark each page so copied with
28
the label or stamp specified in subparagraph 3.2.
49220113;1
1
3.3
Interrogatory Answers. If a party answering an interrogatory or other discovery demand
2
believes that its answer contains Confidential Information, it shall state so in the interrogatory
3
response, and that portion of the response will be entitled to the protections of this order.
4
3.4
Inspection of Documents. In the event a party elects to produce files and records for
5
inspection and the requesting party elects to inspect them, no designation of Confidential Information
6
needs to be made in advance of the inspection. For purposes of such inspection, all material produced
7
shall be considered as Confidential Information. If the inspecting party selects specified documents to
8
be copied, the producing party shall designate Confidential Information in accordance with
9
subparagraph 3.2 at the time the copies are produced.
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
10
3.5
Deposition Transcripts. The party asserting confidentiality shall state on the record the
11
portions it deems confidential. The failure to designate testimony on the record as confidential shall
12
be a waiver unless the designating party notifies all other parties and files a motion to designate the
13
testimony as confidential within 5 days of the notification.
14
3.6
Inadvertent Failure to Designate. Inadvertent failure to identify documents or things as
15
"Confidential" pursuant to this Protective Order shall not constitute a waiver of any otherwise valid
16
claim for protection, provided that the provisions of this paragraph are satisfied. If the designating
17
party discovers that information should have but was not designated "Confidential" or if the
18
designating party receives notice that would enable the designated party to learn that it has disclosed
19
such information, the designating party must immediately notify all other parties. in such event, within
20
thirty (30) days of notifying all other parties, the designating parties must also provide copies of the
21
"Confidential" information designated in accordance with this Protective Order. After receipt of such
22
re-designated information, the "Confidential" information shall be treated as required by this
23
Protective Order, and the receiving party(ies) shall promptly, and in no event more than fourteen (14)
24
calendar days from the receipt of the re-designated information, return to the designated party all
25
previously produced copies of the same unlegended documents or things. The designating party and
26
the parties may agree to alternative means. The receiving party(ies) shall receive no liability, under
27
this Protective Order or otherwise, for any disclosure of information contained in unlegended
28
documents or things occurring before the receiving party was placed on notice of the designating
49220113;1
1
party's claims of confidentiality.
2
4.
3
Designations by Another Party.
4.1
Notification of Designation. If a party other than the producing party believes that a
4
producing party has produced a document that contains or constitutes Confidential Information of the
5
non-producing party, the non-producing party may designate the document as Confidential
6
Information by so notifying all parties in writing within fourteen (14) days of service of the document.
7
4.2
Return of Documents, Non-disclosure. Whenever a party other than the producing party
subparagraph 4.1, each party receiving the document shall either add the Confidential Information
10
AKERMAN LLP
designates a document produced by a producing party as Confidential Information in accordance with
9
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
8
designation in accordance with subparagraph 3.2 or substitute a copy of the document bearing such
11
designation for each copy of the document produced by the producing party. Each party shall destroy
12
all undesignated copies of the document or return those copies to the producing party, at the direction
13
of the producing party. No party shall disclose a produced document to any person, other than the
14
persons authorized to receive Confidential Information under subparagraph 7.1, until after the
15
expiration of the fourteen (14) day designation period specified in subparagraph 4.1. If during the
16
fourteen (14) day designation period a party discloses a produced document to a person authorized to
17
receive Confidential Information under subparagraph 7.1, and that document is subsequently
18
designated as Confidential Information in accordance with subparagraph 4.1, the disclosing party shall
19
cause all copies of the document to be destroyed or returned to the producing party, at the direction of
20
the producing party. The party may thereafter disclose a copy of the document that has been marked
21
as Confidential Information by the designating party, in accordance with subparagraphs 3.2 and 7.1.
22
5.
Objections to Designations. Any party objecting to a designation of Confidential
23
Information, including objections to portions of designations of multi-page documents, shall notify the
24
designating party and all other parties of the objection in writing forty-five (45) days before trial of
25
the matter. This notice must specifically identify each document that the objecting party in good faith
26
believes should not be designated as Confidential Information and provide a brief statement of the
27
grounds for such belief. In accordance with the Federal Rules of Civil Procedure governing discovery
28
disputes, the objecting and the designating parties thereafter shall confer within ten (10) days after the
49220113;1
1
date of such objection in an attempt to resolve their differences. If the parties are unable to resolve
2
their differences, the designating party shall have fourteen (14) days after the conference concludes to
3
file with the Court a motion to deem the information as Confidential Information. Where a party
4
authored, created, owns, or controls a document, information or other material that another party
5
designates as Confidential Information, the party that authored, created, owns, or controls the
6
Confidential Information may so inform the objecting party and thereafter shall also be considered a
7
designating party for purposes for this paragraph.
Information shall be treated as such in accordance with this Protective Order unless and until the Court
10
AKERMAN LLP
All documents, information and other materials initially designated as Confidential
9
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
8
rules otherwise, except for deposition transcripts and exhibits initially considered as containing
11
Confidential Information under subparagraph 3.5, which will lose their confidential status after
12
fourteen (14) days unless so designated as Confidential Information. If the Court rules that a
13
designation should be maintained as to a particular document, the producing party shall, upon written
14
request by a party, provide that party a copy of that document without the designation described in
15
subparagraph 3.2.
16
17
The objecting party shall bear the burden of proof to establish the information or document is
not entitled to the Confidential Information designation.
18
If a designating party elects not to make such a motion with respect to documents within
19
fourteen (14) days after the conference, information or other materials to which an objection has been
20
made, the Confidential Information designated shall be deemed withdrawn. The objecting party shall
21
have fourteen (14) days to respond to the objecting party's motion. If no response is filed by the
22
objecting party within fourteen (14) days, the objecting party shall be deemed to have consented to the
23
designating party's motion.
24
6.
Custody. All Confidential Information and any and all copies, extracts and summaries
25
thereof, including memoranda relating thereto, shall be retained by the receiving party in the custody
26
of counsel of record, or by persons to whom disclosure is authorized under subparagraph 7.1.
27
7.
Handling Prior to Trial.
28
7.1
Authorized Disclosures. Confidential Information shall be disclosed by the receiving
49220113;1
1
party only to the following persons:
2
3
a.
and secretarial personnel;
4
5
b.
Qualified persons taking testimony in this litigation involving such Confidential
Information, and necessary stenographic, videotape and clerical personnel;
6
7
Counsel for the parties in this litigation, including their associates, clerks, paralegals,
c.
Experts and their staff who are retained by counsel as expert witnesses for a party in
this litigation;
8
d.
Experts and their staff who are consulted by counsel for a party in this litigation;
9
e.
Parties to this litigation, limited to the named party and, if that party is a corporate
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
10
entity, a limited number of employees of the corporate entity and its insurers;
11
12
f.
otherwise;
13
14
Designated in-house counsel and a limited number of assistants, administrative or
g.
Outside vendors employed by counsel for copying, scanning and general handling of
documents;
15
h.
Any person of whom testimony is taken regarding the Confidential Information, except
16
that such person may only be shown Confidential Information during his/her testimony, and may not
17
retain a copy of such Confidential Information; and
18
19
i.
under seal.
20
21
This Court and this Court's staff, subject to the Court's processes for filing materials
Such disclosures are authorized only to the extent necessary to investigate, prosecute, or defend
the litigation.
22
Confidential Information may not be disclosed to persons under subparagraphs (c) or (d) until
23
the receiving party has obtained a written acknowledgment from the person receiving Confidential
24
Information, in the form of the Declaration attached hereto as Exhibit A, that he or she has received a
25
copy of this Protective Order and has agreed to be bound by it. A party who discloses Confidential
26
Information in accordance with subparagraph 7.1 shall retain the written acknowledgment from each
27
person receiving Confidential Information, shall maintain a list of all persons to whom a receiving
28
party has disclosed Confidential Information and identify what documents have been disclosed, and
49220113;1
1
shall furnish the written acknowledgments and disclosure list to opposing counsel as follows: (i) for a
2
person under subparagraph (c), within thirty (30) days after the person signs the Declaration, and (ii)
3
for a person under subparagraph (d), within thirty (30) days after the matter is finally concluded.
4
Disclosure of Confidential Information to this Court including judicial staff, shall be made in
5
accordance with subparagraph 7.4 of this Protective Order.
6
7.2
Unauthorized Disclosures. All persons receiving Confidential Information under the
located in Nevada for all matters arising from the improper disclosure or use of such information. If
9
Confidential Information is disclosed to any person other than in the manner authorized by this
10
AKERMAN LLP
terms of this Protective Order are under the jurisdiction of the state courts and U.S. federal courts
8
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
7
Protective Order, the party or person responsible for the disclosure, and any other party or person who
11
is subject to this Protective Order and learns of such disclosure, shall immediately bring such
12
disclosure to the attention of the designating party. Without prejudice to other rights and remedies of
13
the designating party, the responsible party or person shall make every effort to obtain and return the
14
Confidential Information and to prevent further disclosure on its own part or on the part of the person
15
who was the unauthorized recipient of such information.
16
7.3
Court Filings. In the event any Confidential Information must be filed with the Court
17
prior to trial, the proposed filing shall be accompanied by a motion to file the Confidential Information
18
under seal that complies with Local Rule 10-5(b) and proposed order, and the application and proposed
19
order shall be directed to the judge to whom the Confidential Information is directed. This provision
20
is applicable to briefs, memoranda, and other filings which quote, summarize, or describe Confidential
21
Information.
22
8.
Care in Storage. Any person in possession of Confidential Information produced by
23
another party shall exercise reasonable and appropriate care with regard to the storage, custody,
24
copying, and use of such information to ensure that the confidential and sensitive nature of same is
25
maintained.
9.
26
Handling During Trial. Confidential Information that is subject to this Order may be
27
marked and used as trial exhibits by either party, subject to terms and conditions as imposed by the
28
Court upon application by any party.
49220113;1
1
10.
No Implied Waivers. This Protective Order shall not be interpreted as a waiver of the
2
right to object, under applicable law, to the furnishing of information in response to discovery requests
3
or to object to a requested inspection of documents or facilities. Parties producing Confidential
4
Information in this litigation are doing so only pursuant to the terms of this Protective Order. The
5
taking of any action in accordance with the provisions of this Protective Order shall not be interpreted
6
as a waiver of any claim or position or defense in this action, or any other actions.
7
11.
No Admission. The designation of any item as Confidential Information shall not be
8
construed as an admission that such material, or any testimony concerning such material, would be
9
admissible in evidence in this litigation or in any other proceeding.
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
10
12.
Inadvertent Disclosure. Nothing in this Protective Order abridges applicable law
11
concerning inadvertent disclosure of a document that the Disclosing Party believes contains attorney-
12
client communications, attorney work product or otherwise privileged information. If a party
13
inadvertently discloses documents or information subject to a claim of privilege or work product
14
protection under applicable law. Upon discovery by the Receiving Party, or receipt of written notice
15
from the Disclosing Party identifying privileged or protected Documents that were inadvertently
16
produced, the receiving party shall within seven (7) business days either: (a) return or certify the
17
destruction of all such documents, all copies, and any work product or portions of any work-product
18
containing or reflecting the contents of the subject materials, or (b) after attempting to resolve any
19
dispute with opposing counsel informally, file a motion to challenge the assertion of privilege and
20
tender the subject documents for in camera review with the motion. The moving party shall do nothing
21
to compromise the privilege claim until the Court rules on said motion and the opportunity for
22
appellate review is exhausted or the issue is otherwise resolved.
13.
23
Parties' Own Documents. This Protective Order shall in no way restrict the parties in
24
their use of their own documents and information, and nothing in this Protective Order shall preclude
25
any party from voluntarily disclosing its own documents or information to any party or nonparty.
14.
26
Motion by Third Party to Compel Production of Confidential Information. If any
27
third party subpoenas Confidential Information from a party to this action or moves to compel a party
28
to this action to produce any such information, such party shall immediately notify the parties who
49220113;1
has been made in order to allow the parties who originally produced and/or designated such
3
information the opportunity to seek a protective order or oppose the motion or application. If, within
4
thirty (30) days after receiving notice of a subpoena seeking Confidential Information from a receiving
5
party, the party who originally produced and/or designated such information fails to move for a
6
protective order, the party subject to the subpoena may produce said information. In addition, if a party
7
is ordered to produce Confidential Information covered by this Protective Order, then notice and, if
8
available, a copy of the order compelling disclosure shall immediately be given the parties who
9
originally produced and/or designated such information. Nothing in this Protective Order shall be
10
AKERMAN LLP
originally produced and/or designated such information that a subpoena has been served or a motion
2
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
1
construed as requiring the party who is ordered to produce such Confidential Information to challenge
11
or appeal any order requiring the production of such information or to subject himself/herself to any
12
penalty for non-compliance with any legal process or seek any relief from the Court.
13
15.
No Effect on Other Rights. This Protective Order shall in no way abrogate or diminish
14
any pre-existing contractual, statutory, or other legal obligations or rights of any party with respect to
15
Confidential Information.
16.
16
Modification. In the event any party hereto seeks a Court order to modify the terms
17
of this Protective Order, or seeks a protective order which incorporates the terms and conditions of
18
this Protective Order said party shall make such request by written stipulation or noticed motion to all
19
parties that must be served and filed in accordance with local court rules.
20
17.
Handling Upon Conclusion of Litigation. All parties, counsel, and person to whom
21
disclosure was made agree to return all Confidential Information to the designating party within thirty
22
(30) days of the conclusion of litigation between the parties, including final appellate action or the
23
expiration of time to appeal or seek further review. In addition, counsel shall certify in writing that all
24
such Confidential Information have been returned. Counsel for each party also shall contact each
25
person to whom that party has provided a copy of any Confidential Information and request the
26
documents be returned. In lieu of returning Confidential Information, the person or party in possession
27
of such information may elect to destroy it. If the person or party in possession of Confidential
28
Information elects to destroy it rather than return it, that person or party must notify the designating
49220113;1
1
party in writing of the destruction of the information within ninety (90) days of the conclusion of
2
litigation between the parties, including final appellate action or the expiration of time to appeal or
3
seek further review.
4
18.
Survival of the Terms of this Protective Order. Even after the termination of this
5
litigation, the confidentiality obligations imposed by this Protective Order shall remain in effect until
6
a Designating Party otherwise in writing or a court order otherwise directs.
7
8
9
AKERMAN LLP
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
10
11
12
13
14
15
16
17
18
19
20
21
22
DATED June 19, 2019.
AKERMAN LLP
LIPSON NEILSON P.C.
/s/ Scott Lachman
DARREN T. BRENNER, ESQ.
Nevada Bar No. 8386
SCOTT R. LACHMAN, ESQ.
Nevada Bar No. 12016
1635 Village Center Circle, Suite 200
Las Vegas, Nevada 89134
Attorneys for plaintiff and counter-defendant
U.S. Bank, N.A., as Trustee for the Holders of the
CSFB Mortgage Securities Corp., Adjustable
Rate Mortgage Loan Trust 2005-8, Adjustable
Rate Mortgage-Backed Pass-Through
Certificates, Series 2005-8
/s/ David Ochoa
KALEB D. ANDERSON, ESQ.
Nevada Bar No. 7582
JOSEPH P. GARIN, ESQ.
Nevada Bar No. 6653
DAVID T. OCHOA, ESQ.
Nevada Bar No. 10414
9900 Covington Cross Drive, Suite 120
Las Vegas, Nevada 89144
Attorneys for defendant Countryside
Homeowners Association
AYON LAW, PLLC
/s/ Luis Ayon
LUIS A. AYON, ESQ.
Nevada Bar No. 9752
8716 Spanish Ridge Ave., Suite 115
Las Vegas, Nevada
Attorneys for defendant and counter-claimant
KK Real Estate Investment Fund, LLC
23
ORDER
24
IT IS SO ORDERED.
25
26
______________________________________
UNITED STATES MAGISTRATE JUDGE
27
28
June 20, 2019
DATED:_______________________________
49220113;1
1
EXHIBIT A
2
ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND
issued by the United States District Court, for the District of Nevada, on ________________, 2019,
5
in the case of U.S. Bank, National Association, as Trustee for the Holders of the CSFB Mortgage
6
Securities Corp., Adjustable Rate Mortgage Trust 2005-8, Adjustable Rate Mortgage-Backed Pass-
7
Through Certificates Series 2005-8 v. Countryside Homeowners Association, et al, Case No. 2:15-cv-
8
01463-RCJ-GWF. I agree to comply with and be bound by all terms of this Protective Order and I
9
understand and acknowledge that failure to so comply could expose me to sanctions and punishment
10
AKERMAN LLP
I, ______________________, and read in its entirety and understand the Protective Order
4
1635 VILLAGE CENTER CIRCLE, SUITE 200
LAS VEGAS, NEVADA 89134
TEL.: (702) 634-5000 – FAX: (702) 380-8572
3
in the nature of contempt. I solemnly promise that I will not disclose in any manner any information
11
or item that is subject to this Protective Order to any person or entity except in strict compliance with
12
this Protective Order. Further, I solemnly promise that I will not offer to sell, advertise or publicize
13
that I have obtained any protected material subject to this Protective Order.
14
At the conclusion of this matter, I will return all protected materials which came into my
15
possession or control to counsel for the party from whom I received the protected material, or I will
16
destroy those materials.
17
summaries of protected material shall remain protected pursuant to the terms of this Order.
I understand that any confidential information contained within any
18
I further agree to submit to the jurisdiction of the United States District Court, for the District
19
of Nevada for the purpose of enforcing the terms of this Protective Order, even if such enforcement
20
proceedings occur after termination of this action.
21
I certify under penalty of perjury that the foregoing is true and correct.
22
Date: ____________________________
23
City and State where signed: ________________________________
24
Printed Name: ___________________________________________
25
Address: ________________________________________________
26
Signature: _______________________________________________
27
28
49220113;1
Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.
Why Is My Information Online?