Upshaw v. Nationwide Mutual Insurance Company

Filing 21

AGREED PROTECTIVE ORDER. Signed by Magistrate Judge Chelsey M. Vascura on 5/22/2018. (kpt)

IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
FRANCIS WOODROW, individually and
on behalf of all others similarly situated,
Plaintiffs,
v.
NATIONWIDE BANK,
Defendant.

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Case No. 2:17-cv-01013
Chief Judge Edmund A. Sargus
Magistrate Judge Chelsey M. Vascura

AGREED PROTECTIVE ORDER
This matter having come before the Court by agreement of the undersigned parties that a
protective order intended to limit the review, copying, dissemination and filing of confidential
documents and information produced by any party, or produced by or obtained from any nonparty, in the course of discovery should be entered; the parties, by, between and among their
respective counsel having agreed to the terms set forth herein and good cause having been
shown; it is hereby ORDERED, ADJUDGED and DECREED that:
1.

This Agreed Protective Order is being entered to facilitate the production,

exchange and discovery of documents, materials and information produced in response to any
discovery request in this action or Court Order, or obtained from non-parties, including but not
limited to, documents and other materials and information obtained through document requests,
interrogatories, requests to admit or subpoena or in response to any Court Order, as well as any
affidavit and deposition testimony, or transcript thereof, given in this action or documents or
other materials marked as exhibits at any deposition, which the Designating Party believes in

good faith merits confidential treatment (hereinafter collectively the “Document,” “Documents,”
or “Testimony”).
2.

As used herein, “Confidential Information” subject to this Protective Order shall

include all Documents and Testimony, and the information or materials contained therein, if such
Documents and Testimony contain: (a) proprietary business information and/or other
confidential research, development, or commercial information; (b) information required to be
kept confidential or protected pursuant to the Gramm-Leach-Bliley Act, any rules or regulations
promulgated thereunder including 16 C.F.R. Part 314, and any applicable state law equivalents;
(c) competitively sensitive information, including, without limitation, information that reveals
trade secrets; (d) customer data, including, without limitation, nonpublic personal information as
defined in 16 CFR 313.3(n) about a customer; (e) personal identifying information and/or nonpublic information regarding individuals, employees, customers, clients, and other persons
and/or non-parties including, without limitation, social security numbers, telephone numbers,
account numbers, or other personal financial information (collectively referred to as “personal
identifying information” or “PII”); or (f) medical information concerning any individual.
3.

As used herein, “Attorneys’ Eyes Only Information” includes highly competitive

sensitive information, trade secrets, proprietary business information, PII, or other information
the disclosure of which to any person not authorized by this Agreed Protective Order, in the good
faith judgment of the party designating the material as “Attorneys’ Eyes Only Information,”
would result in significant competitive injury to the Designating Party’s business or operations.
4.

Any Producing Party or Designating Party (if not the same) may designate a

Document or Documents as Confidential Information for protection under this Order by placing
or affixing the words “CONFIDENTIAL – SUBJECT TO PROTECTIVE ORDER,” or

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something similar, on the Document and all copies in a manner that will not interfere with the
legibility of the Document. As used in this Order, “copies” includes all electronic images,
duplicates, extracts, summaries or descriptions that contain the Confidential Information. Any
Producing Party or Designating Party (if not the same) may designate a Document or Documents
as Attorneys’ Eyes Only Information for protection under this Order by placing or affixing the
words “ATTORNEYS’ EYES ONLY INFORMATION – SUBJECT TO PROTECTIVE
ORDER,” or something similar, on the Document and all copies in a manner that will not
interfere with the legibility of the Document.

In the case of Confidential Information or

Attorneys’ Eyes Only Information disclosed in a non-paper medium (e.g., videotape, audiotape,
computer disks, etc.), the appropriate designation shall be affixed on the outside of the medium
or its container so as to clearly give notice of the designation.
5.

Unless all parties agree on the record at the time the deposition testimony is taken,

all deposition testimony taken in this case shall be treated as Confidential Information until the
expiration of the following: No later than the thirtieth day after the official transcript is delivered
to any party or the witness, a party may serve a Notice of Designation to all parties of record as
to specific portions of the testimony that are designated Confidential Information and/or
Attorneys’ Eyes Only Information, and thereafter only those portions identified in the Notice of
Designation shall be protected by the terms of this Order. Additionally, a party may designate a
Document, or Documents, or Testimony as Attorneys’ Eyes Only Information by stating on the
record of a deposition that the Document or Testimony constitutes Attorneys’ Eyes Only
Information. If a Designating Party has advised the court reporter that Confidential Information
or Attorneys’ Eyes Only Information has been disclosed during the deposition, the court reporter

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shall include on the cover page the following indication: “Deposition Contains Confidential or
Attorneys’ Eyes Only Information Subject to Protective Order.”
6.

As used herein, “Producing Party” shall mean the parties to this action and any

non-parties (and their respective counsel) producing Confidential Information or Attorneys’ Eyes
Only Information in connection with depositions, discovery requests, subpoenas or otherwise.
7.

“Designating Party” shall mean any party designating Documents or Testimony,

or any information or materials contained therein, as Confidential Information or Attorneys’
Eyes Only Information, regardless of who produced the Documents or Testimony.
8.

“Receiving Party” shall mean the parties to this action and any non-parties (and

their respective counsel) receiving Confidential Information or Attorneys’ Eyes Only
Information in connection with depositions, discovery requests, subpoenas or otherwise.
9.

A Receiving Party may designate portions of Documents or Testimony as

Confidential Information or Attorneys’ Eyes Only Information, and request that any Confidential
Information or Attorneys’ Eyes Only Information contained within the Documents or Testimony
be redacted, within 30 days of the receipt of the Documents or Testimony, if the Producing Party
has not already done so.
10.

A party may object to the designation of any Document or Testimony (or any

portion thereof) as Confidential Information or Attorneys’ Eyes Only Information by giving
written notice to both the Producing Party and any Designating Party (if not the same). The
written notice shall identity the Document or Testimony (or portion thereof) to which the
objection is made. The parties shall, within fourteen (14) days of service of the written objection,
confer concerning the objection. If the objection is not resolved, it shall be the obligation of the
party objecting to the designation of the Document or Testimony (or portion thereof) as

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Confidential Information or Attorneys’ Eyes Only Information to file, no later than fourteen (14)
days after the parties’ meet and confer, an appropriate motion requesting that the Court
determine whether the disputed Document or Testimony (or portion thereof) should be subject to
the terms of this Protective Order. In response to any such motion, the Producing Party or
Designating Party shall bear the burden of establishing the confidentiality of any disputed
material designated as Confidential Information or Attorneys’ Eyes Only Information. The
disputed designated Documents or Testimony shall continue to be treated consistently with their
initial designation unless and until the Court rules otherwise.
11.

Except with the prior written consent of both the Producing Party and any

Designating Party (if not the same) or by Order of the Court, Confidential Information shall not
be furnished, shown or disclosed to any person or entity except to:
(a)

the named parties and their personnel actually engaged in assisting in the
preparation of this action for trial or other proceeding herein, provided such
persons have been advised of their obligations hereunder;

(b)

counsel for the parties to this action and their associated attorneys, paralegals and
other professional personnel (including support staff or third-party document
support vendors or database/coding services) who are directly assisting such
counsel in the preparation of this action for trial or other proceeding herein, are
under the supervision or control of such counsel, and have been advised by such
counsel of their obligations hereunder;

(c)

any expert retained for consulting or testifying purposes, as well as all assistants,
stenographic, and clerical employees working under the supervision of such
experts in connection with this action, provided such persons have executed the

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attached Agreement to Respect Confidential Information and Attorneys’ Eyes
Only Information (Exhibit A hereto);
(d)

The Court and its personnel, subject to the restrictions of Paragraph 20;

(e)

Court reporters, videographers, and their clerical personnel in connection with
work on this action, provided such persons have executed the attached Agreement
to Respect Confidential Information and Attorneys’ Eyes Only Information
(Exhibit A hereto);

(f)

deponents, witnesses, or potential witnesses, provided such persons have executed
the attached Agreement to Respect Confidential Information and Attorneys’ Eyes
Only Information (Exhibit A hereto);

(g)

any mediator and the mediator’s personnel (including support staff) who are
directly assisting the mediator in connection with this action, provided, however,
the mediator and the mediator’s personnel shall execute the Agreement to Respect
Confidential Information and Attorneys’ Eyes Only Information (Exhibit A
hereto); and

(h)

any other person authorized to have access by Order of the Court, or by written
agreement of the Producing Party and any Designating Party (if not the same).

12.

Except with the prior written consent of both the Producing Party and any

Designating Party (if not the same) or by Order of the Court, Attorneys’ Eyes Only Information
shall not be furnished, shown or disclosed to any person or entity except to:
(a)

counsel (not including in-house counsel) for the parties to this action and their

associated attorneys, paralegals and other professional personnel (including support staff or
third-party document support vendors) who are directly assisting such counsel in the preparation

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of this action for trial or other proceeding herein, are under the supervision or control of such
counsel, and who have been advised by such counsel of their obligations hereunder;
(b)

the Court and its personnel, subject to the restriction of Paragraph 20;

(c)

subject to the limitations of Paragraph 16, any expert retained for consulting or

testifying purposes, as well as all assistants, stenographic, and clerical employees working under
the supervision of such experts, provided such persons have executed the attached Agreement to
Respect Confidential Information and Attorneys’ Eyes Only Information (Exhibit A hereto);
(d)

Court reporters, videographers, and their clerical personnel in connection with

work on this action, provided such persons have executed the attached Agreement to Respect
Confidential Information and Attorneys’ Eyes Only Information (Exhibit A hereto);
(e)

any deponent may be shown or examined on any information, document or thing

designated Attorneys’ Eyes Only Information if it appears that the deponent authored or received
a copy of it, was involved in the subject matter described therein or is employed by the party
who produced the information, provided such person has executed the attached Agreement to
Respect Confidential Information and Attorneys’ Eyes Only Information (Exhibit A hereto); and
(f)

any other person agreed to in writing by the Producing Party and any Designating

Party (if not the same).
13.

If a person to whom the disclosure of Confidential Information or Attorneys’ Eyes

Only Information is contemplated hereunder fails to or refuses to sign the Agreement to Respect
Confidential Information and Attorneys’ Eyes Only Information (Exhibit A hereto), the parties
shall work cooperatively to obtain a prompt hearing before the Court to resolve any issues of
confidentiality, so that the ultimate resolution of the case cannot be delayed.

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14.

Confidential Information and Attorneys’ Eyes Only Information shall be utilized

by the Receiving Party and any other party receiving Confidential Information or Attorneys’
Eyes Only Information only for purposes of the above-captioned litigation, including appeals,
and for no other purposes, including, but not limited to, for purposes of other business interests
or other litigation.
15.

Should the need arise for any of the parties to disclose Confidential Information

or Attorneys’ Eyes Only Information during any hearing or trial before the Court, including
through argument or the presentation of evidence, the parties shall confer and attempt to agree
beforehand on the procedures under which Confidential Information or Attorneys’ Eyes Only
Information may be introduced into evidence or otherwise used at such hearing or trial. Upon
reaching agreement, the parties shall give notice of the terms of such agreement to each
non-party who has produced Confidential Information or Attorneys’ Eyes Only Information
which may be used or introduced at such hearing or trial, as well as the Court.

Absent

agreement, the Court shall be asked to issue an order governing the use of such Confidential
Information or Attorneys’ Eyes Only Information at any hearing or trial upon reasonable notice
to all parties and non-parties who have produced such information.
16.

Before any disclosure of Attorneys’ Eyes Only Information is made to an expert

witness or consultant pursuant to Paragraph 12(c), the Receiving Party must first identify in
writing the expert to whom it intends to give or disclose such Attorneys’ Eyes Only Information
to the attorneys for the Producing Party and any Designating Party (if not the same), who shall
have ten (10) days from receipt of such notice to object to disclosure to any of the experts so
identified, setting forth in writing the reason for the objection. Such identification shall include,
at least: (1) the full name and professional address and/or affiliation of the proposed expert; and

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(2) a current curriculum vitae identifying, at least, all other present employments or
consultancies of the expert and employments or consultancies for the previous four (4) years.
The parties shall attempt to resolve any objections informally. If the objections cannot be
resolved, it shall be the obligation of the party objecting to the disclosure of Attorneys’ Eyes
Only Information to file, no later than fourteen (14) days after the parties’ meet and confer, an
appropriate motion seeking an appropriate Protective Order.

The party objecting to the

disclosure shall bear the burden of proving that the disclosure is inappropriate.
17.

Counsel shall maintain the originals of the forms signed by persons

acknowledging their obligations under this Order for a period of three years after the termination
of the case.
18.

Nothing herein shall be deemed in any way to restrict the use of Documents or

Testimony which are publicly available to a party independent of discovery in this litigation,
whether or not the same material has been obtained during the course of discovery in this
litigation and whether or not such Documents or Testimony have been designated as
Confidential Information or Attorneys’ Eyes Only Information.
19.

Nothing herein shall be deemed to limit or prohibit a Designating Party's use of its

own information, even if that information has been designated as Confidential Information or
Attorneys’ Eyes Only Information, and such use shall not be deemed to waive the designation of
any material as Confidential Information or Attorneys’ Eyes Only Information.
20.

Subject to Paragraph 20(a), no unredacted Confidential Information and/or

Attorneys’ Eyes Only Information shall be filed in the public record of this action, unless the
Producing Party or any Designating Party (if not the same) has agreed to withdraw the
Confidential Information or Attorneys’ Eyes Only Information designation, the Court has ruled

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that the information or material is not Confidential Information, or the Court otherwise directs
for good cause. Nothing prohibits any party from filing in the public record of this action a copy
of a Document or Testimony where the Confidential Information and/or Attorneys’ Eyes Only
Information has been redacted.
(a)

Pursuant to Local Rule 5.2.1(a), any party seeking to file with the Court

Documents or Testimony designated as unredacted Confidential Information and/or Attorneys’
Eyes Only Information, or any materials disclosing the contents of such Documents or
Testimony, must first obtain leave of Court. Upon obtaining leave of Court, litigants must file
the documents electronically using the ECF system as provided in Local Rule 5.1. Nothing in
this Order shall prohibit a party from filing appropriately redacted copies of information publicly
with the Court. Nothing prohibits any party from filing in the public record of this action a copy
of a Document or Testimony where the Confidential Information and/or Attorneys’ Eyes Only
Information has been redacted.
(b)

A copy of any Document filed under seal may also be delivered to the judicial

officer’s chambers in a securely sealed envelope (or other securely sealed container) on which
shall be endorsed the caption of the litigation, a descriptive title of the document, the date of the
filing, and the words “DOCUMENTS UNDER SEAL” or the equivalent as a conspicuous
indication of the nature of the documents.
21.

Any person receiving Confidential Information or Attorneys’ Eyes Only

Information shall not reveal or discuss such information to, or with, any person not entitled to
receive such information under the terms hereof and shall protect such information against
inadvertent disclosure to any person not permitted to view such materials under the terms of this
Order, including without limitation, keeping paper documents and electronic media under lock

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and key and keeping electronic files in a system that provides appropriate security against
unauthorized access.
22.

Any Document or Testimony that has been inadvertently not designated as

Confidential Information or Attorneys’ Eyes Only Information as provided in this Agreed
Protective Order, or is produced by a non-party without identification as Confidential
Information or Attorneys’ Eyes Only Information but that a party determines should be
designated as Confidential Information or Attorneys’ Eyes Only Information, may be so
designated by written notice to all other parties’ counsel identifying the Document or Testimony
as Confidential Information or Attorneys’ Eyes Only Information within a reasonable time
following the discovery that the Document or Testimony has been produced without such
designation.
23.

Pursuant to Civil Rule 26(b)(5)(B) and Federal Rule of Evidence 502, the

inadvertent production of any Document or Testimony during discovery in this action shall be
without prejudice to any claim that such material is protected by the attorney-client privilege, the
work product doctrine, or any other applicable privilege or ground for withholding production,
and no party shall be held to have waived any rights by such inadvertent production. Upon
written notice of such an inadvertent production, the Receiving Party shall make no further use
of the Document or information until further order of the Court.
24.

Nothing in this Agreed Protective Order shall operate to require the production of

Documents or Testimony that are subject to a good faith assertion of attorney-client privilege,
the attorney work product doctrine, or other privilege or protection from disclosure.

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25.

Extracts, summaries, compilations, notes, copies, electronic images or databases

of Confidential Information or Attorneys’ Eyes Only Information shall also be treated in
accordance with the provisions of this Agreed Protective Order.
26.

Except on privilege grounds, no party may withhold information from discovery

on the ground that it requires protection greater than that afforded by this Order unless the party
moves for an order providing such special protection after the parties have made a reasonable
effort to resolve the issue. However, the production or disclosure of Confidential Information or
Attorneys’ Eyes Only Information shall in no way constitute a waiver of any party’s right to
object to the production or disclosure of information in this action or in any other action,
including, but not limited to, objecting to production on the basis of relevance, burdensomeness,
presence of trade secrets, presence of personal identifying information, presence of ulterior
motives and/or improper purpose by the party requesting the materials, and/or the existence of
contractual or other legal requirements to protect confidentiality of certain requested information.
27.

If counsel for any party receives notice of any subpoena or other compulsory

process commanding production of Confidential Information or Attorneys’ Eyes Only
Information that a party has obtained under the terms of this Agreed Protective Order, counsel
for such party (a) shall notify the Producing Party and any Designating Party (if not the same) in
writing at least five days prior to the compliance due date (if there are fewer than ten days to
comply) or at least seven days prior to the due date (if there are more than ten days to comply);
(b) shall cooperate to the extent necessary to permit the Producing Party or any Designating
Party (if not the same) to seek to quash such process or discovery request; and (c) shall not
produce the Confidential Information or Attorneys’ Eyes Only Information until the Producing
Party and any Designating Party (if not the same) has had reasonable time to take appropriate

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steps to protect the material, and, where steps are taken to obtain relief from the subpoena or
order, to obtain a final ruling thereon. The party from whom such information is sought shall in
any event not make the disclosure before the actual due date of compliance set forth in the
subpoena or order or any extended date for compliance.
28.

Absent prior written consent of both parties and affected non-parties, this Agreed

Protective Order shall continue to be binding after the conclusion of this litigation except (a) that
there shall be no restriction on Documents or Testimony that are used as exhibits in Court (unless
such exhibits were filed or used under seal); and (b) that a party may seek the written permission
of the Producing Party and any Designating Party (if not the same) or further order of the Court
with respect to dissolution or modification of any portion of the Agreed Protective Order.
29.

Nothing herein shall be deemed an admission as to the relevance or admissibility

in evidence of any facts, Documents, Testimony or other materials revealed in the course of
disclosure.
30.

Nothing herein shall be deemed to prejudice in any way a party’s ability to

present a motion to the Court for a separate protective order, including, but not limited to, a
motion seeking restrictions different from those specified herein, nor shall it prejudice any
party’s ability to present a motion that the confidentiality of information protected under this
order should be lifted.
31.

Nothing herein shall constitute a waiver of any party’s claims or defenses.

32.

Within sixty (60) days after the final termination of this and all other litigation

between the parties hereto by settlement or exhaustion of all appeals, all Confidential
Information and Attorneys’ Eyes Only Information produced or designated and all reproductions
thereof, shall be returned to the Producing Party and any Designating Party (if not the same) or

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shall be destroyed. In the event that any party chooses to destroy Documents or Testimony
containing Confidential Information or Attorneys’ Eyes Only Information, such party shall
certify in writing within sixty (60) days of the final termination of this litigation that it has
undertaken its best efforts to destroy such Documents or Testimony containing Confidential
Information or Attorneys’ Eyes Only Information and that such Documents or Testimony
containing Confidential Information or Attorneys’ Eyes Only Information have been destroyed
to the best of its knowledge. Notwithstanding anything to the contrary, counsel of record for the
parties may retain one copy of Documents constituting work product, a copy of pleadings,
motion papers, discovery responses, deposition transcripts and deposition and trial exhibits. This
Agreed Protective Order shall not be interpreted in a manner that would violate any applicable
canons of ethics or applicable codes of professional responsibility.
33.

This Agreed Protective Order is entered into without prejudice to the right of any

party to seek relief from, or modification of, this Agreed Protective Order or any provisions
thereof by properly noticed motion to the Court. This Agreed Protective Order may be changed
by further order of this Court.
34.

If Confidential Information or Attorneys’ Eyes Only Information produced to a

Receiving Party is disclosed or comes into the possession of any person other than in a manner
authorized in this Agreed Protective Order (“Unauthorized Disclosure”), the Receiving Party
shall immediately inform the Producing Party and the Designating Party (if not the same) of all
pertinent facts relating to the Unauthorized Disclosure and the nature and extent of the
Confidential Information or Attorneys’ Eyes Only Information involved. The Receiving Party
shall take all necessary and appropriate actions to retrieve physically or otherwise control all
Confidential Information or Attorneys’ Eyes Only Information that was part of the Unauthorized

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Disclosure and to prevent any further disclosure. The Receiving Party also shall cooperate fully
with all actions that the Producing Party and/or the Designating Party (if not the same)
reasonably believes may be necessary and appropriate to further respond to the Unauthorized
Disclosure.
35.

The Court’s entry of this Agreed Protective Order shall mean that production of

any Confidential or Attorneys’ Eyes Only Information in this action pursuant to this Agreed
Protective Order shall satisfy and shall constitute compliance with the Producing Party’s and/or
Designating Party’s obligations under the Gramm-Leach-Bliley Act, including any rules or
regulations promulgated thereunder, and any applicable state law equivalents, and the disclosure
of any Confidential or Attorneys’ Eyes Only Information in this action pursuant to this Agreed
Protective Order shall constitute disclosure pursuant to 15 U.S.C. § 6802(e)(8) and 16 C.F.R.
313.15(a)(7).
SIGNED AND ENTERED this ______day of ____________________, 2018.

/s/ Chelsey M. Vascura
____________________________________
UNITED STATES
JUDGE
Approved By:
Dated: May 21, 2018
/s/ Michael H. Carpenter
Michael H. Carpenter (0015733)
Trial Attorney
Michael N. Beekhuizen (0065722)
Amber L. Merl (0080655)
Carpenter Lipps & Leland LLP
280 Plaza, Suite 1300
280 North High Street
Columbus, Ohio 43215
Tel: [phone]
Fax: [phone]
[e-mail]
[e-mail]
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[e-mail]
Attorneys for Defendant Nationwide Bank

Dated: May 21, 2018
/s/ Matthew R. Wilson (per email auth., 5/18/18, ALM)
Matthew R. Wilson (0072925)
Michael J. Boyle, Jr. (0091162)
MEYER WILSON CO., LPA
1320 Dublin Road, Ste. 100
Columbus, Ohio 43215
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]
Attorneys for Plaintiff Woodrow and the proposed class

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EXHIBIT “A”
IN THE UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
FRANCIS WOODROW, individually and
on behalf of all others similarly situated,
Plaintiffs,
v.
NATIONWIDE BANK,
Defendant.

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Case No. 2:17-cv-01013
Chief Judge Edmund A. Sargus
Magistrate Judge Chelsey M. Vascura

AGREEMENT TO RESPECT CONFIDENTIAL INFORMATION AND ATTORNEYS’
EYES ONLY INFORMATION
I,

, state that:

1.

My address is

.

2.

My present employer is

.

3.

My present occupation or job description is
.

4.

I have received a copy of the Agreed Protective Order (the “Agreed Protective Order”)

entered in the above-entitled action on

.

5.

I have carefully read and understand the provisions of the Agreed Protective Order.

6.

I will comply with all of the provisions of the Agreed Protective Order.

7.

I will hold in confidence, will not disclose to anyone not qualified under the Agreed

Protective Order, and will use only for purposes of this action, any Confidential Information or
Attorneys’ Eyes Only Information that is disclosed to me.
8.

I will return all Confidential Information or Attorneys’ Eyes Only Information that comes

into my possession, and Documents or things that I have prepared relating thereto, to counsel for
the party by whom I am employed or retained, or to counsel from whom I received the
Confidential Information or Attorneys’ Eyes Only Information.
9.

I hereby submit to the jurisdiction of this court for the purpose of enforcement of the

Agreed Protective Order in this action.

Dated:
Signature

______________________________
Printed name, and if applicable, title

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CERTIFICATE OF SERVICE
This is to certify that a true and accurate copy of the foregoing Agreed Protective Order
was filed through the ECF system this 20th day of May, 2018, and will be sent via the ECF
system to registered participants, including the following:
Matthew R. Wilson
Michael Joseph Boyle, Jr.
Meyer Wilson Co., LPA
Suite 100
1320 Dublin Road
Columbus, OH 43215
[e-mail]
[e-mail]

Anthony Paronich (pro hac vice)
Broderick & Paronich, P.C.
99 High Street, Ste. 304
Boston, Massachusetts 02110
Telephone: [phone].
Facsimile: [phone]
Email: [e-mail]

Counsel for Plaintiff Woodrow

/s/ Michael H. Carpenter
One of the Attorneys for Defendant
Nationwide Bank