Villa et al v. U.S. Bank, N.A. as Trustee for LSF9 Master Participation Trust et al, No. 2:2017cv01957 - Document 35 (D. Nev. 2018)
Court Description: ORDER granting 34 Stipulated Protective Order; Signed by Magistrate Judge Peggy A. Leen on 8/21/2018. (Copies have been distributed pursuant to the NEF - JM)
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Villa et al v. U.S. Bank, N.A. as Trustee for LSF9 Master Participation Trust et al Doc. 35 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 1 of 17 1 2 3 4 5 6 7 8 MELANIE D. MORGAN, ESQ. Nevada Bar No. 8215 SCOTT R. LACHMAN, ESQ. Nevada Bar No. 12016 AKERMAN LLP 1635 Village Center Circle, Suite 200 Las Vegas, Nevada 89134 Telephone: (702) 634-5000 Facsimile: (702) 380-8572 Email: melanie.morgan@akerman.com Email: scott.lachman@akerman.com Attorneys for U.S. Bank, N.A. as Trustee for LSF9 Master Participation Trust, Caliber Home Loans, Inc., and Summit Real Estate Services, LLC 9 UNITED STATES DISTRICT COURT AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 10 DISTRICT OF NEVADA 11 12 BALDOMERO P. VILLA, AND EDERLINDA A. VILLA 13 Plaintiffs, v. 14 15 16 Case No.: 2:17-cv-01957-APG-PAL STIPULATED PROTECTIVE ORDER U.S. BANK, N.A., AS TRUSTEE FOR LSF9 MASTER PARTICIPATION TRUST, CALIBER HOME LOANS, INC., AND SUMMIT REAL ESTATE SERVICES, LLC 17 Defendants. 18 19 Subject to the approval of the Court, Defendants U.S. Bank, N.A., as Trustee for LSF9 20 Master Participation Trust (“U.S. Bank”), Caliber Home Loans, Inc. (“Caliber”), and Summit Real 21 Estate Services, LLC (“Summit”), (collectively “Defendants”), and Plaintiffs Baldomero and 22 Ederlinda Villa’s (collectively “Plaintiffs”) stipulate to the following Protective Order. 23 … 24 … 25 … 26 … 27 … 28 … 1 45708665;1 Dockets.Justia.com AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 2 of 17 1 To expedite the flow of discovery, facilitate the prompt resolution of disputes over 2 confidentiality, adequately protect material claimed to be confidential, and ensure protection is 3 afforded only to material so designated, it is, pursuant to the Court's authority under Nevada Rule of 4 Civil Procedure 26, ORDERED this Protective Order shall govern the disclosure, handling and 5 disposition of documents in this litigation as follows: 6 1. Application. 7 1.1 This Protective Order shall govern any document, information or other material that 8 is designated as containing “Confidential Information” as defined herein, and is produced in 9 connection with this litigation by any person or entity (the “producing party”), whether in response 10 to a discovery request, subpoena or otherwise, to any other person or entity (the “receiving party”) 11 regardless of whether the person or entity producing or receiving such information is a party to this 12 litigation. 13 2. Definitions. 14 2.1 Confidential Information. “Confidential Information” shall mean and include, 15 without limitation, any non-public information that concerns or relates to the following areas: 16 confidential proprietary information, trade secrets, practices and procedures, personal financial 17 information, commercial, financial, pricing, budgeting, and/or accounting information, information 18 about existing and potential customers, marketing studies, performance projections, business 19 strategies, decisions and/or negotiations, personnel compensation, evaluations and other 20 employment information, and confidential or proprietary information about affiliates, parents, 21 subsidiaries and third-parties with whom the parties to this action have or have had business 22 relationships. 23 2.2 Documents. As used herein, the term “documents” includes all writings, records, 24 files, drawings, graphs, charts, photographs, e-mails, video tapes, audio tapes, compact discs, 25 electronic messages, other data compilations from which information can be obtained and other 26 tangible things subject to production under the Nevada Rules of Civil Procedure. 27 … 28 … 2 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 3 of 17 1 3. Initial Designation. 2 3.1 Good Faith Claims. Claims of confidentiality will be made only with respect to 3 documents, other tangible things and information that the asserting party has a good faith belief are 4 within the definition set forth in subparagraph 2.1 of this Protective Order. Objections to such 5 claims made pursuant to paragraph 5, below, shall also be made only in good faith. 6 AKERMAN LLP Produced Documents. A party producing documents that it believes constitute or 7 contain Confidential Information shall state that the material is being produced under this Protective 8 Order by describing the documents or materials to be treated as confidential in writing, by page or 9 bates number wherever possible and/or shall produce copies bearing a label that contains or 10 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 3.2 includes language substantially identical to the following: 11 CONFIDENTIAL 12 This label shall be affixed in a manner that does not obliterate or obscure the contents of the 13 copies. If any person or party makes copies of documents designated as containing Confidential 14 Information, the copying person or party shall mark each such copy as containing Confidential 15 Information in the same form as the Confidentiality notice on the original document. 16 A party producing documents that are stored on electronic, magnetic, optical or other non- 17 paper media, such as compact discs, DVD’s, video tapes and audio tapes (collectively, “data storage 18 devices”) shall designate the data storage device as containing Confidential Information, by affixing 19 a label or stamp to the data storage device in the manner described above at the time copies of such 20 data storage devices are produced. If the receiving party or other persons or entities to whom 21 disclosure is authorized pursuant to subparagraph 7.1 make a copy of any data storage device 22 designated by the producing party as containing Confidential Information, the receiving party or 23 other authorized person shall mark each such copy as containing Confidential Information in the 24 same form as the confidentiality notice on the original data storage device produced. If the 25 receiving party or other authorized person prints out or otherwise makes copies of the documents or 26 information stored on such data storage device, the receiving party or other authorized person shall 27 mark each page so copied with the label or stamp specified in subparagraph 3.2. 28 … 3 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 4 of 17 1 3.3 2 demand believes that its answer contains Confidential Information, it shall state so in the 3 interrogatory response, and that portion of the response will be entitled to the protections of this 4 order. 5 AKERMAN LLP 3.4 Inspection of Documents. In the event a party elects to produce files and records for 6 inspection and the requesting party elects to inspect them, no designation of Confidential 7 Information needs to be made in advance of the inspection. For purposes of such inspection, all 8 material produced shall be considered as Confidential Information. If the inspecting party selects 9 specified documents to be copied, the producing party shall designate Confidential Information in 10 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Interrogatory Answers. If a party answering an interrogatory or other discovery accordance with subparagraph 3.2 at the time the copies are produced. 11 3.5 Deposition Transcripts. The party asserting confidentiality shall state on the record 12 the portions it deems confidential. The failure to designate testimony on the record as confidential 13 shall be a waiver unless the designating party notifies all other parties and files a motion to 14 designate the testimony as confidential within 5 days of the notification. 15 3.6 Inadvertent Failure to Designate. Inadvertent failure to identify documents or things 16 as “Confidential” pursuant to this Protective Order shall not constitute a waiver of any otherwise 17 valid claim for protection, provided that the provisions of this paragraph are satisfied. If the 18 designating party discovers that information should have but was not designated “Confidential” or 19 of the designating party receives notice that would enable the designated party to learn that it has 20 disclosed such information, the designating party must immediately notify all other parties. In such 21 event, within thirty (30) days of notifying all other parties, the designating parties must also provide 22 copies of the “Confidential” information designated in accordance with this Protective Order. After 23 receipt of such re-designated information, the “Confidential” information shall be treated as 24 required by this Protective Order, and the receiving party(ies) shall promptly, and in no event more 25 than fourteen (14) calendar days from the receipt of the re-designated information, return to the 26 designated party all previously produced copies of the same unlegended documents or things. The 27 designating party and the parties may agree to alternative means. The receiving party(ies) shall 28 receive no liability, under this Protective Order or otherwise, for any disclosure of information 4 45708665;1 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 5 of 17 1 contained in unlegended documents or things occurring before the receiving party was placed on 2 notice of the designating party's claims of confidentiality. 3 4. Designations by Another Party. 4 4.1 Notification of Designation. If a party other than the producing party believes that a 5 producing party has produced a document that contains or constitutes Confidential Information of 6 the non-producing party, the non-producing party may designate the document as Confidential 7 Information by so notifying all parties in writing within fourteen (14) days of service of the 8 document. 9 4.2 Return of Documents; Non-disclosure. Whenever a party other than the producing 10 party designates a document produced by a producing party as Confidential Information in 11 accordance with subparagraph 4.1, each party receiving the document shall either add the 12 Confidential Information designation in accordance with subparagraph 3.2 or substitute a copy of 13 the document bearing such designation for each copy of the document produced by the producing 14 party. Each party shall destroy all undesignated copies of the document or return those copies to the 15 producing party, at the direction of the producing party. No party shall disclose a produced 16 document to any person, other than the persons authorized to receive Confidential Information 17 under subparagraph 7.1, until after the expiration of the fourteen (14) day designation period 18 specified in subparagraph 4.1. If during the fourteen (14) day designation period a party discloses a 19 produced document to a person authorized to receive Confidential Information under subparagraph 20 7.1, and that document is subsequently designated as Confidential Information in accordance with 21 subparagraph 4.1, the disclosing party shall cause all copies of the document to be destroyed or 22 returned to the producing party, at the direction of the producing party. The party may thereafter 23 disclose a copy of the document that has been marked as Confidential Information by the 24 designating party, in accordance with subparagraphs 3.2 and 7.1. 25 5. Objections to Designations. Any party objecting to a designation of Confidential 26 Information, including objections to portions of designations of multi-page documents, shall notify 27 the designating party and all other parties of the objection in writing up to and through trial of the 28 matter. This notice must specifically identify each document that the objecting party in good faith 5 45708665;1 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 6 of 17 1 believes should not be designated as Confidential Information and provide a brief statement of the 2 grounds for such belief. In accordance with the Federal Rules of Civil Procedure governing 3 discovery disputes, the objecting and the designating parties thereafter shall confer within ten (10) 4 days after the date of such objection in an attempt to resolve their differences. If the parties are 5 unable to resolve their differences, the objecting party shall have twenty one (21) days after the 6 conference concludes to file with the Court a motion to remove the Confidential Information. If an 7 objection is served within forty-two (42) days of trial, the objecting party must file its motion to 8 remove the Confidential Information designation within half of the remaining time before trial, and 9 the meet-and-confer period shall be shortened accordingly. Where a party authored, created, owns, 10 or controls a document, information or other material that another party designates as Confidential 11 Information, the party that authored, created, owns, or controls the Confidential Information may so 12 inform the objecting party and thereafter shall also be considered a designating party for purposes 13 of this paragraph. 14 All documents, information and other materials initially designated as Confidential 15 Information shall be treated as such in accordance with this Protective Order unless and until the 16 Court rules otherwise, except for deposition transcripts and exhibits initially considered as 17 containing Confidential Information under subparagraph 3.5, which will lose their confidential 18 status after twenty-one (21) days unless so designated as Confidential Information. If the Court 19 rules that a designation should not be maintained as to a particular document, the producing party 20 shall, upon written request by a party, provide that party a copy of that document without the 21 designation described in subparagraph 3.2. 22 If an objecting party elects not to make such a motion with respect to documents within 23 twenty one (21) days after the conference, information or other materials to which an objection has 24 been made, the objection shall be deemed withdrawn. The designating party shall have twenty one 25 (21) days to respond to the objecting party’s motion. If no response is filed by the designating party 26 within twenty one (21) days, the designating party shall be deemed to have consented to the 27 objecting party’s motion pursuant to LR 7-2(d). 28 … 6 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 7 of 17 1 6. 2 summaries thereof, including memoranda relating thereto, shall be retained by the receiving party in 3 the custody of counsel of record, or by persons to whom disclosure is authorized under 4 subparagraph 7.1. 5 7. Handling Prior to Trial. 6 7.1 Authorized Disclosures. Confidential Information shall be disclosed by the receiving 7 party only to the following persons: 8 9 a. AKERMAN LLP 11 b. Qualified persons taking testimony in this litigation involving such Confidential Information, and necessary stenographic, videotape and clerical personnel; 12 13 Counsel for the parties in this litigation, including their associates, clerks, paralegals, and secretarial personnel; 10 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Custody. All Confidential Information and any and all copies, extracts and c. Experts and their staff who are retained by counsel as expert witnesses for a party in this litigation; 14 d. Experts and their staff who are consulted by counsel for a party in this litigation; 15 e. Parties to this litigation, limited to the named party and, if that party is a corporate 16 entity, a limited number of employees of the corporate entity and its insurers; 17 18 f. otherwise; 19 20 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; 21 h. Any person of whom testimony is taken regarding the Confidential Information, 22 except that such person may only be shown Confidential Information during his/her testimony, and 23 may not retain a copy of such Confidential Information; and 24 25 i. This Court and this Court’s staff, subject to the Court’s processes for filing materials under seal. 26 Such disclosures are authorized only to the extent necessary to investigate, prosecute, or 27 defend the litigation. 28 … 7 45708665;1 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 8 of 17 1 Confidential Information may not be disclosed to persons under subparagraphs (c) or (d) 2 until the receiving party has obtained a written acknowledgment from the person receiving 3 Confidential Information, in the form of the Declaration attached hereto as Exhibit A, that he or she 4 has received a copy of this Protective Order and has agreed to be bound by it. A party who discloses 5 Confidential Information in accordance with subparagraph 7.1 shall retain the written 6 acknowledgment from each person receiving Confidential Information, shall maintain a list of all 7 persons to whom a receiving party has disclosed Confidential Information and identify what 8 documents have been disclosed, and shall furnish the written acknowledgments and disclosure list 9 to opposing counsel as follows: (i) for a person under subparagraph (c), within thirty (30) days after 10 the person signs the Declaration; and (ii) for a person under subparagraph (d), within thirty (30) 11 days after the matter is finally concluded. Disclosure of Confidential Information to this Court, 12 including judicial staff, shall be made in accordance with subparagraph 7.4 of this Protective Order. 13 7.2 Unauthorized Disclosures. All persons receiving Confidential Information under the 14 terms of this Protective Order are under the jurisdiction of the state courts and U.S. federal courts 15 located in Nevada for all matters arising from the improper disclosure or use of such information. If 16 Confidential Information is disclosed to any person other than in the manner authorized by this 17 Protective Order, the party or person responsible for the disclosure, and any other party or person 18 who is subject to this Protective Order and learns of such disclosure, shall immediately bring such 19 disclosure to the attention of the designating party. Without prejudice to other rights and remedies 20 of the designating party, the responsible party or person shall make every effort to obtain and return 21 the Confidential Information and to prevent further disclosure on its own part or on the part of the 22 person who was the unauthorized recipient of such information. 23 7.3 Court Filings. In the event any Confidential Information must be filed with the Court 24 prior to trial, the proposed filing shall be accompanied by a motion to file the Confidential 25 Information under seal that complies with Local Rule 10-5(b) and a proposed order, and the 26 application and proposed order shall be directed to the judge to whom the Confidential Information 27 is directed. This provision is applicable to briefs, memoranda, and other filings which quote, 28 summarize, or describe Confidential Information. 8 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 9 of 17 1 8. 2 another party shall exercise reasonable and appropriate care with regard to the storage, custody, 3 copying, and use of such information to ensure that the confidential and sensitive nature of same is 4 maintained. 5 9. AKERMAN LLP Handling During Trial. Confidential Information that is subject to this Order may 6 be marked and used as trial exhibits by either party, subject to terms and conditions as imposed by 7 the Court upon application by any party. 8 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Care in Storage. Any person in possession of Confidential Information produced by 10. No Implied Waivers. This Protective Order shall not be interpreted as a waiver of 9 the right to object, under applicable law, to the furnishing of information in response to discovery 10 requests or to object to a requested inspection of documents or facilities. Parties producing 11 Confidential Information in this litigation are doing so only pursuant to the terms of this Protective 12 Order. The taking of any action in accordance with the provisions of this Protective Order shall not 13 be interpreted as a waiver of any claim or position or defense in this action, or any other actions. 14 11. No Admission. The designation of any item as Confidential Information shall not be 15 construed as an admission that such material, or any testimony concerning such material, would be 16 admissible in evidence in this litigation or in any other proceeding. 17 12. Inadvertent Disclosure. Nothing in this Protective Order abridges applicable law 18 concerning inadvertent disclosure of a document that the Disclosing Party believes contains 19 attorney-client communications, attorney work product, or otherwise privileged information. If a 20 party inadvertently discloses documents or information subject to a claim of privilege or work 21 product protection, such disclosure will not waive otherwise applicable claims of privilege or work 22 product protection under applicable law. Upon discovery by the Receiving Party, or receipt of 23 written notice from the Disclosing Party identifying privileged or protected Documents that were 24 inadvertently produced, the receiving party shall within seven (7) business days either: (a) return or 25 certify the destruction of all such documents, all copies, and any work product or portions of any 26 work product containing or reflecting the contents of the subject materials; or (b) after attempting to 27 resolve any dispute with opposing counsel informally, file a motion to challenge the assertion of 28 privilege and tender the subject documents for in camera review with the motion. The moving party 9 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 10 of 17 1 shall do nothing to compromise the privilege claim until the Court rules on said motion and the 2 opportunity for appellate review is exhausted or the issue is otherwise resolved. 3 13. 4 in their use of their own documents and information, and nothing in this Protective Order shall 5 preclude any party from voluntarily disclosing its own documents or information to any party or 6 nonparty. AKERMAN LLP 7 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Parties' Own Documents. This Protective Order shall in no way restrict the parties 14. Motion by Third Party to Compel Production of Confidential Information. If 8 any third party subpoenas Confidential Information from a party to this action or moves to compel a 9 party to this action to produce any such information, such party shall immediately notify the parties 10 who originally produced and/or designated such information that a subpoena has been served or a 11 motion has been made in order to allow the parties who originally produced and/or designated such 12 information the opportunity to seek a protective order or oppose the motion or application. If, 13 within thirty (30) days after receiving notice of a subpoena seeking Confidential Information from a 14 receiving party, the party who originally produced and/or designated such information fails to move 15 for a protective order, the party subject to the subpoena may produce said information. In addition, 16 if a party is ordered to produce Confidential Information covered by this Protective Order, then 17 notice and, if available, a copy of the order compelling disclosure shall immediately be given the 18 parties who originally produced and/or designated such information. Nothing in this Protective 19 Order shall be construed as requiring the party who is ordered to produce such Confidential 20 Information to challenge or appeal any order requiring the production of such information or to 21 subject himself/herself to any penalty for non-compliance with any legal process or seek any relief 22 from the Court. 23 15. No Effect on Other Rights. This Protective Order shall in no way abrogate or 24 diminish any pre-existing contractual, statutory, or other legal obligations or rights of any party 25 with respect to Confidential Information. 26 27 16. Modification. In the event any party hereto seeks a Court order to modify the terms of this Protective Order, or seeks a protective order which incorporates the terms and conditions of 28 10 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 11 of 17 1 this Protective Order said party shall make such request by written stipulation or noticed motion to 2 all parties that must be served and filed in accordance with local court rules. AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 3 17. Handling Upon Conclusion of Litigation. All parties, counsel, and persons to 4 whom disclosure was made agree to return all Confidential Information to the designating party 5 within thirty (30) days of the conclusion of litigation between the parties, including final appellate 6 action or the expiration of time to appeal or seek further review. In addition, counsel shall certify in 7 writing that all such Confidential Information have been returned. Counsel for each party also shall 8 contact each person to whom that party has provided a copy of any Confidential Information and 9 request the documents be returned. In lieu of returning Confidential Information, the person or party 10 in possession of such information may elect to destroy it. If the person or party in possession of 11 Confidential Information elects to destroy it rather than return it, that person or party must notify 12 the designating party in writing of the destruction of the information within ninety (90) days of the 13 conclusion of litigation between the parties, including final appellate action or the expiration of 14 time to appeal or seek further review. 15 … 16 … 17 … 18 … 19 … 20 … 21 … 22 … 23 … 24 … 25 … 26 … 27 … 28 … 11 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 12 of 17 1 18. Survival of the Terms of this Protective Order. Even after the termination of this 2 litigation, the confidentiality obligations imposed by this Protective Order shall remain in effect until 3 a Designating Party otherwise in writing or a court order otherwise directs. 4 DATED this 25th day of July, 2018. 5 AKERMAN LLP 6 /s/ Scott R. Lachman_____________________ MELANIE D. MORGAN, ESQ. Nevada Bar No. 8215 SCOTT R. LACHMAN, ESQ. Nevada Bar No. 12016 1635 Village Center Circle, Suite 200 Las Vegas, Nevada 89134 7 8 9 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 10 DATED this 25th day of July, 2018. /s/ Baldomero Villa and Ederlinda Villa BALDOMERO P. VILLA EDERLINDA A. VILLA 1978 Alcova Ridge Drive Las Vegas, Nevada 89135 Plaintiffs Attorneys for Defendants 11 12 ORDER 13 14 IT IS SO ORDERED. 15 August 21, 2018 Dated: ___________________________ 16 17 ----------------------------------------------------------MAGISTRATE JUDGE 18 19 20 21 22 23 24 25 26 27 28 12 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 13 of 17 1 Exhibit A 2 3 4 5 6 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 23 24 25 26 27 28 13 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 14 of 17 1 2 3 4 5 6 7 8 MELANIE D. MORGAN, ESQ. Nevada Bar No. 8215 SCOTT R. LACHMAN, ESQ. Nevada Bar No. 12016 AKERMAN LLP 1635 Village Center Circle, Suite 200 Las Vegas, Nevada 89134 Telephone: (702) 634-5000 Facsimile: (702) 380-8572 Email: melanie.morgan@akerman.com Email: scott.lachman@akerman.com Attorneys for U.S. Bank, N.A. as Trustee for LSF9 Master Participation Trust, Caliber Home Loans, Inc., and Summit Real Estate Services, LLC 9 DISTRICT COURT AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 10 CLARK COUNTY, NEVADA 11 12 BALDOMERO P. VILLA, AND EDERLINDA A. VILLA 13 Plaintiffs, v. 14 15 16 Case No.: 2:17-cv-01957-APG-PAL DECLARATIONS U.S. BANK, N.A., AS TRUSTEE FOR LSF9 MASTER PARTICIPATION TRUST, CALIBER HOME LOANS, INC., AND SUMMIT REAL ESTATE SERVICES, LLC 17 Defendants. 18 19 20 … 21 … 22 … 23 … 24 … 25 … 26 … 27 … 28 14 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 15 of 17 1 DECLARATION 2 3 I hereby declare that I have read the Stipulated Protective Order entered in the abovecaptioned action and that I understand the terms thereof. 4 I agree to be bound by the Stipulated Protective Order. 5 I further agree to submit to the jurisdiction of this Court for purposes of enforcing the 6 Stipulated Protective Order, and I understand that the Court may impose sanctions on me for any 7 violation of the Stipulated Protective Order. 8 Dated: July 25, 2018 9 /s/ Baldomero Villa____________________ 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 23 24 25 26 27 28 15 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 16 of 17 1 DECLARATION 2 3 I hereby declare that I have read the Stipulated Protective Order entered in the abovecaptioned action and that I understand the terms thereof. 4 I agree to be bound by the Stipulated Protective Order. 5 I further agree to submit to the jurisdiction of this Court for purposes of enforcing the 6 Stipulated Protective Order, and I understand that the Court may impose sanctions on me for any 7 violation of the Stipulated Protective Order. 8 Dated: July 25, 2018 9 /s/ Ederlinda Villa _____________________ 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 23 24 25 26 27 28 16 45708665;1 Case 2:17-cv-01957-APG-PAL Document 34 Filed 07/25/18 Page 17 of 17 1 DECLARATION 2 3 I hereby declare that I have read the Stipulated Protective Order entered in the abovecaptioned action and that I understand the terms thereof. 4 I agree to be bound by the Stipulated Protective Order. 5 I further agree to submit to the jurisdiction of this Court for purposes of enforcing the 6 Stipulated Protective Order, and I understand that the Court may impose sanctions on me for any 7 violation of the Stipulated Protective Order. 8 Dated: July 25, 2018 9 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 10 _/s/ Scott Lachman __________________ 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 17 45708665;1
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