Resolute International Services, Inc. v. Bazgadze et al, No. 2:2023cv00984 - Document 16 (D. Nev. 2024)
Court Description: ORDER Granting 15 Stipulation for the Production and Exchange of Natallia Bazgadzes Confidential JPMorgan Chase Bank Information and Records. Signed by Magistrate Judge Elayna J. Youchah on 3/1/2024. (Copies have been distributed pursuant to the NEF - RJDG)
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Resolute International Services, Inc. v. Bazgadze et al 1 2 3 4 Doc. 16 HECTOR J. CARBAJAL II Nevada Bar No. 6247 CARBAJAL LAW 10001 Park Run Drive Las Vegas, Nevada 89145 Telephone: (702) 846-0040 Facsimile: (702) 846-1329 E-mail: hector@claw.vegas 5 Attorney for Defendants 6 UNITED STATES DISTRICT COURT 7 CLARK COUNTY, NEVADA 8 9 RESOLUTE INTERNATIONAL SERVICES INC., a Nevada corporation; Plaintiff, 10 11 v. 12 NATALLIA BAZGADZE, an individual; H TANDEM, LLC, a North Carolina limited liability company; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive; 13 14 15 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Defendants. Case No.: 2:23-cv-00984 16 17 18 19 20 21 STIPULATION AND ORDER FOR THE PRODUCTION AND EXCHANGE OF NATALLIA BAZGADZE’S CONFIDENTIAL JPMORGAN CHASE BANK INFORMATION AND RECORDS WHEREAS, the parties to the above-captioned action (the “Litigation”) are engaged in discovery proceedings, which include, among other things, taking depositions and producing documents; and 22 WHEREAS, Plaintiff Resolute International Services Inc. served a notice of subpoena 23 to subpoena to JPMorgan Chase Bank, N.A. on February 1, 2024 (the “Subpoena”) for the 24 production of certain information that the parties to the Litigation (the “Parties,” each a 25 “Party”) believe to be confidential and sensitive commercial, financial, or business 26 information; 27 IT IS HEREBY STIPULATED AND AGREED, by the Parties hereto, through their 28 undersigned counsel, subject to the approval of the Court, pursuant to Rule 26 of the Federal 1 Dockets.Justia.com 1 Rules of Civil Procedure, that this Stipulation and Order for the Production and Exchange of 2 Confidential Information (the “Stipulation”) will govern the handling of documents, 3 deposition testimony, deposition exhibits, deposition transcripts, written discovery requests, 4 interrogatory responses, responses to requests to admit, and responses to requests for 5 documents, and any other information or material produced, given or exchanged, including 6 7 8 9 any information contained therein or derived therefrom strictly related to the Subpoena or Previously Produced Records (“Discovery Material”) by or among any Party or non-Party providing Discovery Material (each a “Producing Party”) in this Litigation. IT IS HEREBY STIPULATED AND AGREED, by the Parties hereto, through their 10 undersigned counsel, subject to the approval of the Court, pursuant to Rule 26 of the Federal 11 12 13 14 15 Rules of Civil Procedure, that this Stipulation shall only apply to the Subpoena and to no other materials in the case. 1. Any Producing Party may designate any Discovery Material as “Confidential” under the terms of this Stipulation if such party in good faith believes that such Discovery 16 Material contains non-public, confidential, proprietary, or commercially sensitive information 17 that requires the protections provided in this Stipulation (“Confidential Discovery Material”). 18 19 20 2. The designation of Discovery Material as Confidential Discovery Material shall be made in the following manner: A. In the case of documents or other materials (apart from depositions or other 21 pre-trial testimony): (i) by affixing the legend “Confidential” to each page 22 containing any Confidential Discovery Material (including each page of any 23 electronic documents produced in TIFF, PDF, or similar format); or (ii) in the 24 case of electronically stored information (“ESI”) produced in native format, by 25 including “Confidential” in the file or directory name, or by affixing the legend 26 “Confidential” to the media containing the Discovery Material (e.g., CD- 27 28 ROM, flash drive, DVD). To the extent that any ESI designated as Confidential Discovery Material does not contain any indication of such designation when 2 1 printed in hard-copy or any other form, a receiving Party shall use its best 2 efforts to ensure that such Confidential Discovery Material is treated in 3 compliance with this Stipulation. Any Party may request that any Discovery 4 Material be designated as Confidential Discovery Material. 5 B. 6 In the case of depositions or other pre-trial testimony: (i) by a statement on the record, by counsel, at the time of such disclosure or before the conclusion of 7 the testimony; or (ii) by written notice, sent to all Parties designating the 8 testimony with sufficient particularity that the testimony so designated may be 9 readily identified. From the date of the deposition or other pre-trial testimony 10 through the period ending thirty (30) calendar days after the delivery of the 11 final transcript of such testimony, the entire transcript (as well as any videotape 12 or other recording thereof) shall be treated as Confidential Discovery Material. 13 Thereafter, unless a Party has designated all or part of the testimony as 14 Confidential Discovery Material at the deposition or within the 30-day period, 15 16 none of the testimony in the transcript or any videotape or other recording 17 thereof shall be treated as Confidential Discovery Material. Nothing in this 18 provision precludes a Party from subsequently designating all or part of 19 deposition of other pre-trial testimony as Confidential Discovery Material after 20 the 30-day period has passed. The Parties may modify this procedure for any 21 particular deposition or other pre-trial testimony, through agreement on the 22 record at such deposition or testimony, without further order of the Court. 23 C. 24 25 26 27 28 In the case of any other Discovery Material, by written notice that the Discovery Material constitutes Confidential Discovery Material. 3. The designation and labeling of Discovery Material as Confidential Discovery Material or as Attorneys’ Eyes Only Discovery Material (as defined in Paragraph 8 of this Stipulation) shall constitute a representation that such Discovery Material has been reviewed by an attorney representing the Party making the designation, and that there is a good faith 3 1 basis for such designation pursuant to Paragraphs 1, 2 and/or 8 of this Stipulation. If qualified 2 Discovery Materials cannot be designated or labeled pursuant to Paragraph 2 of this 3 Stipulation, they shall be designated as Confidential or Attorneys’ Eyes only, as the case may 4 be, in a manner to be agreed upon by the parties. 5 4. Inadvertent failure to designate Discovery Material as Confidential Discovery 6 Material or Attorneys’ Eyes Only Discovery Material shall not constitute a waiver of such 7 claim and may be corrected. A Producing Party may designate as Confidential or Attorneys’ 8 9 10 11 12 13 14 15 Eyes Only any Discovery Material that has already been produced, including Discovery Material that the Producing Party inadvertently failed to designate as Confidential or Attorneys’ Eyes Only, (i) by notifying in writing the Party to whom the production has been made that the Discovery Material constitutes Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material, or (ii) in a manner consistent with Paragraph 2. Upon receiving such supplemental notice, the Parties shall thereafter mark and treat the Discovery Material so designated as Confidential Discovery Material or Attorneys’ Eyes Only Discovery 16 Material, and such Discovery Material shall be fully subject to this Stipulation from the date 17 of such supplemental notice forward. The Party receiving such notice shall make a reasonable, 18 good-faith effort to ensure that any analyses, memoranda, notes, or other such materials 19 generated based upon such newly designated information are immediately treated as 20 containing Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material. In 21 addition, upon receiving such supplemental written notice, any receiving Party that disclosed 22 the Discovery Material prior to its designation as “Confidential” or “Attorneys’ Eyes Only” 23 shall exercise its best efforts (i) to ensure the return or destruction of such Discovery Material, 24 (ii) to ensure that any documents or other materials derived from such Discovery Material are 25 treated as if the Discovery Material had been designated as “Confidential” or “Attorneys’ 26 Eyes Only” when originally produced, (iii) to ensure that such Discovery Material is not 27 28 further disclosed except in accordance with the terms of this Stipulation, and (iv) to ensure that any such Discovery Material, and any information derived therefrom, is used solely for 4 1 2 the purposes described in Paragraph 10 of this Stipulation. 5. Confidential Discovery Material may be disclosed, summarized, described, 3 characterized, or otherwise communicated or made available in whole or in part only to the 4 following persons: 5 A. 6 The Parties and the directors, officers, and employees of the Parties, or any subsidiary or affiliate thereof, who are assisting with or making decisions 7 concerning the Litigation, only to the extent deemed reasonably necessary by 8 counsel of record for the purpose of assisting in the prosecution or defense of 9 Litigation for use in accordance with this Stipulation; 10 B. Counsel who represent Parties in this Litigation (including in-house counsel), 11 and the partners, associates, paralegals, secretaries, clerical, regular and 12 temporary employees, and service vendors of such counsel (including outside 13 copying and litigation support services) who are assisting with the Litigation 14 for use in accordance with this Stipulation; 15 16 C. Subject to Paragraph 6, experts or consultants assisting counsel for the Parties, 17 and partners, associates, paralegals, secretaries, clerical, regular and temporary 18 employees, and service vendors of such experts or consultants (including 19 outside copying services and outside support services) who are assisting with 20 the Litigation; 21 D. Subject to Paragraph 7, witnesses or deponents other than those individuals 22 referenced in Sub-paragraph 5(A), and their counsel, only to the extent 23 necessary to conduct or prepare for depositions or testimony in this Litigation; 24 25 26 27 E. Any person indicated on the face of a document or accompanying covering letter, email, or other communication to be the author, addressee, or an actual or intended recipient of the document, or, in the case of meeting minutes, an attendee of the meeting; 28 5 1 F. 2 3 The Court, persons employed by the Court, and court reporters transcribing any hearing, trial, or deposition in this Litigation or any appeal therefrom; and G. Any other person only upon (i) order of the Court entered upon notice to the 4 Parties, or (ii) written stipulation of, or statement on the record by, the 5 Producing Party who provided the Discovery Material being disclosed, 6 provided that such person signs an undertaking in the form attached as Exhibit 7 8 9 A hereto. 6. Notwithstanding Paragraph 5(C) above, Confidential Discovery Material may be provided to persons listed therein only to the extent necessary for such expert or consultant 10 to prepare a written opinion, to prepare to testify, or to assist counsel in this Litigation, 11 12 13 14 15 provided that such expert or consultant is using said Discovery Material solely in connection with this Litigation; and further provided that such expert or consultant agrees to be bound by the terms of this Stipulation by signing an undertaking in the form attached as Exhibit A hereto. Counsel for the Party showing, providing, or disclosing Confidential Discovery 16 Material to any person required to execute an undertaking pursuant to this paragraph shall be 17 responsible for obtaining such signed undertaking and retaining the original, executed copy 18 thereof. 19 7. Notwithstanding Paragraph 5(D), Confidential Discovery Material may be 20 provided to persons listed therein only after (i) they confirm their understanding and 21 agreement to abide by the terms of this Stipulation by making such a statement on the record, 22 and/or by signing an undertaking in the form attached as Exhibit A hereto, or (ii) a court of 23 competent jurisdiction orders them to abide by the terms of this Stipulation. Counsel for the 24 Party showing Confidential Discovery Material to any person required to execute an 25 undertaking pursuant to this paragraph shall be responsible for obtaining such signed 26 27 28 undertaking and retaining the original, executed copy thereof. 8. Each Party shall have the right to designate as highly confidential and proprietary any Discovery Material or portion thereof produced by it which it believes in good 6 1 faith contains highly sensitive confidential and proprietary commercial, business, financial, 2 or personnel information (“Attorneys’ Eyes Only Discovery Material”). The designation of 3 Discovery Material as “Attorneys’ Eyes Only” shall be made in the same manner as 4 designating Discovery Material as “Confidential” under Paragraphs 2 and 3 of this 5 Stipulation. 6 7 8 9 9. Notwithstanding Paragraph 5 of this Stipulation, access to Attorneys’ Eyes Only Discovery Material or any part thereof and the matters contained therein, is limited to the following persons: A. Attorneys of record, including in-house counsel, for the Parties, and their 10 partners, associates, assistants, paralegals, and other persons regularly 11 employed by attorneys of record for the Parties; 12 13 B. of this action, pursuant to the terms of Paragraph 6 above. 14 15 Consultants and experts retained by the Parties or their attorneys for purposes 10. Discovery Material shall be used solely for purposes of this Litigation and shall 16 not be used for any other purpose, including, without limitation, any business or commercial 17 purpose, or any other litigation or proceeding; provided, however, that the foregoing shall not 18 apply to Discovery Material that is or becomes part of the public record. 19 11. Any Party issuing a subpoena to a non-Party shall enclose a copy of this 20 Stipulation and notify the non-Party that the protections of this Stipulation are available to 21 such non-Party. 22 12. Any pleading, brief, memorandum, motion, letter, affidavit, or other document 23 filed with the Court (a “Filing”) that discloses, summarizes, describes, characterizes, or 24 otherwise communicates Confidential Discovery Material or Attorneys’ Eyes Only Discovery 25 Material (a “Filing Under Seal”) must be filed with the Court under seal in accordance with 26 27 28 this order which addressed the requirements of the provisions of Rules 5 and 5.2 of the Federal Rules of Civil Procedure and LR IA 10-5. No separate motion for leave to file sealed documents will be required as set forth in LR IA10-5 given this order of the Court. 7 1 13. During the pendency of this Litigation, any Party objecting to or challenging 2 the designation of any Discovery Material or testimony as Confidential Discovery Material 3 or Attorneys’ Eyes Only Discovery Material may, after making a good-faith effort to resolve 4 any such objection, move on reasonable notice for an order vacating the designation. While 5 such an application is pending, the Discovery Material or testimony in question shall be 6 treated as Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material, as 7 8 9 applicable, pursuant to this Stipulation. The provisions of this Stipulation are not intended to shift any burdens of proof, including the burden of establishing that any Discovery Material validly constitutes Confidential Discovery Material or Attorneys’ Eyes Only Discovery 10 Material, which burden remains on the party that designates such Discovery Material or 11 12 13 14 15 16 testimony as Confidential or as Attorneys’ Eyes Only. No Party shall be obliged to challenge the propriety of a Confidential or Attorneys’ Eyes Only designation at the time of production of Discovery Materials, and failure to do so shall not preclude a subsequent challenge to the propriety of such designation. 14. The Parties reserve the right to apply, pursuant to Rule 26(c) of the Federal 17 Rules of Civil Procedure, upon short notice, for an order seeking additional safeguards with 18 respect to the use and handling of Discovery Material or to modify the terms of this 19 Stipulation. 20 21 22 15. Entering into this Stipulation, or agreeing to and/or producing or receiving Discovery Material or otherwise complying with the terms of this Stipulation, shall not: A. Prejudice in any way the rights of any Party to (i) seek production of 23 documents or information it considers subject to discovery, or (ii) object to the 24 production of documents or information it considers not subject to discovery; 25 B. 26 27 28 Prejudice in any way the rights of any Party to object to the authenticity or admissibility into evidence of any Discovery Material; C. Operate as an admission by any Party that any particular Discovery Material constitutes Confidential Discovery Material or Attorneys’ Eyes Only 8 1 Discovery Material or contains or reflects trade secrets or any other type of 2 confidential information; 3 D. Prejudice in any way the rights of any Party to (i) petition the Court for a 4 further protective order relating to any purportedly Confidential Discovery 5 Material or Attorneys’ Eyes Only Discovery Material, or (ii) seek a 6 determination by the Court whether any Discovery Material, Confidential 7 Discovery Material, or Attorneys ‘Eyes Only Discovery Material should be 8 9 subject to the terms of this Stipulation; E. Prevent any Party from agreeing in writing to alter or waive the provisions or 10 protection provided herein with respect to any particular Discovery Material; 11 12 F. authenticity, use, or admissibility into evidence of any document, testimony, 13 or other evidence subject to this Stipulation; 14 15 G. H. Operate as a waiver of any attorney-client, work product, business strategy, trade secret, or other privilege. 18 19 Preclude any Party from objecting to discovery that it believes to be otherwise improper; or 16 17 Prejudice in any way the rights of any Party to object to the relevance, 16. This Stipulation has no effect upon, and shall not apply to, a Producing Party’s 20 use or disclosure of its own Discovery Material for any purpose. Nothing herein shall: (i) 21 prevent a Producing Party from disclosing its own Discovery Material; or (ii) impose any 22 restrictions on the use or disclosure by any person of documents, materials, or information 23 designated as Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material 24 obtained lawfully by such person independently of the discovery proceedings in this 25 Litigation, and not otherwise subject to confidentiality restrictions. 26 27 28 17. If Discovery Material that is subject to a claim of attorney-client privilege, attorney work product, or any other applicable privilege or immunity or ground on which production of that information should not be made to any Party (“Inadvertent Production 9 1 Material”) is inadvertently produced to that Party or Parties, such inadvertent production shall 2 in no way prejudice or otherwise constitute a waiver of, or estoppel as to, any claim of 3 attorney-client privilege, work product, or other applicable privilege or immunity. 4 A. 5 Producing Party that the Inadvertent Production Material has been reviewed 6 by an attorney for such Producing Party and that there is a good faith basis for 7 8 A claim of inadvertent production shall constitute a representation by that such claim of inadvertent production. B. 9 If a claim of inadvertent production is made pursuant to this Stipulation, with respect to Discovery Material then in the custody of another Party, the Party 10 possessing the Inadvertent Production Material shall: (i) refrain from any 11 further examination or disclosure of the claimed Inadvertent Production 12 Material; (ii) if requested, promptly make a good-faith effort to return the 13 claimed Inadvertent Production Material and all copies thereof (including 14 summaries and excerpts) to counsel for the Producing Party, or destroy all such 15 16 claimed Inadvertent Production Material(including summaries and excerpts) 17 and all copies thereof, and certify in writing to that fact; and (iii) not use the 18 Inadvertent Production Material for any purpose until further order of the 19 Court. 20 C. A Party may move the Court for an order compelling production of the claimed 21 Inadvertent Production Material; however, while such motion is pending, the 22 Discovery Material in question shall be treated as Inadvertent Production 23 Material, and such motion may not assert as a ground for entering such an 24 order the fact or circumstance of the inadvertent production, nor shall such 25 motion include or otherwise disclose, as an attachment, exhibit, or otherwise, 26 27 the Inadvertent Production Material (or any portion thereof) that is the subject of such motion. 28 10 1 2 3 18. Nothing herein shall be deemed to waive any applicable common law or statutory privilege or work product protection. 19. In the event additional Parties join or are joined in this Litigation, they shall 4 not have access to Confidential Discovery Material or Attorneys’ Eyes Only Discovery 5 Material until the newly joined Party by its counsel has executed and filed with the Court its 6 7 8 9 agreement to be fully bound by this Stipulation. 20. The Parties agree to be bound by the terms of this Stipulation pending the entry by the Court of this Stipulation, and any violation of its terms shall be subject to the same sanctions and penalties as if this Stipulation had been entered by the Court. 10 21. The provisions of this Stipulation shall, absent written permission of the 11 12 13 14 15 Producing Party or further order of the Court, continue to be binding throughout and after the conclusion of the Litigation, including, without limitation, any appeals therefrom. 22. In the event that any Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material is used in open court during any court proceeding or filed as a trial exhibit, 16 the material shall lose its confidential status and become part of the public record, unless the 17 Producing Party applies for and obtains an order from this Court specifically maintaining the 18 confidential status of particular material. Prior to any court proceeding in which Confidential 19 Discovery Material or Attorneys’ Eyes Only Discovery Material is to be used, counsel shall 20 confer in good faith on such procedures that may be necessary or advisable to protect the 21 confidentiality of any such Discovery Material. 22 23. Within 30 days after receiving notice of the entry of an order, judgment, or 23 decree finally disposing of this Litigation, or any other proceeding in which Confidential 24 Discovery Material or Attorneys’ Eyes Only Discovery Material is permitted to be used, 25 including the exhaustion of all possible appeals, and upon the written request of the Producing 26 Party, all persons having received Confidential Discovery Material or Attorneys’ Eyes Only 27 28 Discovery Material shall either (i) make a good-faith and reasonable effort to return such material and all copies thereof (including summaries, excerpts, and derivative works) to 11 1 counsel for the Producing Party; or (ii) make a good-faith and reasonable effort to destroy all 2 such Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material, and 3 certify to that fact in writing to counsel for the Producing Party. However, counsel for the 4 Parties shall be entitled to retain court papers, deposition and trial transcripts, and litigation 5 files (including attorney work product and discovery material containing Confidential 6 Discovery Material or Attorneys’ Eyes Only Discovery Material), provided that such counsel, 7 8 9 10 and employees of such counsel, shall maintain the confidentiality thereof and shall not disclose such court papers, depositions and trial transcripts, and litigation files (including attorney work product and discovery material containing Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material) to any person except pursuant to a court order or 11 12 13 14 15 agreement by the Producing Party or except as otherwise required by law. All materials returned to the Parties or their counsel by the Court likewise shall be disposed of in accordance with this paragraph. 24. If any person in possession of Confidential Discovery Material or Attorneys’ 16 Eyes Only Discovery Material (the “Receiver”) receives a subpoena or other compulsory 17 process seeking the production or other disclosure of Confidential Discovery Material or 18 Attorneys’ Eyes Only Discovery Material produced or designated as “Confidential” or 19 “Attorneys’ Eyes Only” by a Producing Party other than the Receiver (collectively, a 20 “Demand”), the Receiver shall give written notice (by hand, email, or facsimile transmission) 21 to counsel for the Producing Party (or Producing Parties) within three business days of receipt 22 of such Demand (or if a response to the Demand is due in less than three business days, at 23 least 24 hours prior to the deadline for a response to the Demand), identifying the Confidential 24 Discovery Material or Attorneys’ Eyes Only Discovery Material sought and enclosing a copy 25 of the Demand, and must object to the production of the Confidential Discovery Material or 26 Attorneys’ Eyes Only Discovery Material or on the grounds of the existence of this 27 28 Stipulation. The burden of opposing the enforcement of the Demand will fall on the Producing Party. Nothing herein shall be construed as requiring the Receiver or anyone else covered by 12 1 this Stipulation to challenge or appeal any order requiring production of Confidential 2 Discovery Material or Attorneys’ Eyes Only Discovery Material covered by this Stipulation, 3 or to subject itself to any penalties for noncompliance with any legal process or order, or to 4 seek any relief from this Court or any other court. Compliance by the Receiver with any order 5 directing production pursuant to a Demand of any Confidential Discovery Material or 6 Attorneys’ Eyes Only Discovery Material will not constitute a violation of this Stipulation. 7 8 9 25. No Receiver shall reveal any Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material, or the information contained therein, to anyone not entitled to receive such Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material 10 under the terms of this Stipulation. In the event that Confidential Discovery Material or 11 12 13 14 15 Attorneys’ Eyes Only Discovery Material is disclosed to any person other than in the manner authorized by this Stipulation, or that any information comes to the Receiver’s attention that may indicate there was or is likely to be a loss of confidentiality of any Confidential Discovery Material or Attorneys’ Eyes Only Discovery Material, the Receiver responsible for the 16 disclosure or loss of confidentiality shall immediately inform the Producing Party of all 17 pertinent facts relating to the disclosure or loss of confidentiality, including, if known, the 18 name, address, and employer of each person to whom the disclosure was made. The Receiver 19 responsible for the disclosure or loss of confidentiality shall also make reasonable efforts to 20 prevent disclosure of Confidential Discovery Material or Attorneys’ Eyes Only Discovery 21 Material by each unauthorized person who receives the information. 22 ... 23 ... 24 ... 25 ... 26 27 ... ... 28 13 1 26. The Parties agree that the production of any Discovery Material or Attorneys’ 2 Eyes Only Discovery Material by any non-Party shall be subject to and governed by the terms 3 of this Stipulation. 4 5 6 7 8 DATED this 29th day of February, 2024. DATED this 29th day of February, 2024. TAKOS LAW GROUP, LTD. CARBAJAL LAW /s/ Zachary P. Takos Zachary P. Takos, Esq. Nevada Bar No. 111293 Steven R. Hart, Esq. Nevada Bar No. 15418 10785 W. Twain Avenue, Suite 224 Las Vegas, Nevada 89135 Counsel for Plaintiff /s/ Hector J. Carbajal II Hector J. Carbajal II, Esq. Nevada Bar No, 6247 10001 Park Run Drive Las Vegas, Nevada 89145 9 10 11 12 13 14 Counsel for Defendants 15 16 17 IT IS SO ORDERED. 18 19 20 UNITED STATES MAGISTRATE JUDGE DATE: March 1, 2024 21 22 23 24 25 26 27 28 14 1 2 3 4 5 EXHIBIT A 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 15 1 UNITED STATES DISTRICT COURT 2 CLARK COUNTY, NEVADA 3 RESOLUTE INTERNATIONAL SERVICES INC., a Nevada corporation; 4 Plaintiff, 5 v. 6 7 8 NATALLIA BAZGADZE, an individual; H TANDEM, LLC, a North Carolina limited liability company; DOES I through X, inclusive; and ROE CORPORATIONS I through X, inclusive; 9 Defendants. 10 11 12 ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: 2:23-cv-00984 AGREEMENT TO BE BOUND BY STIPULATION AND ORDER FOR THE PRODUCTION AND EXCHANGE OF NATALLIA BAZGADZE’S CONFIDENTIAL JPMORGAN CHASE BANK INFORMATION AND RECORDS 13 I have read the Stipulation and Order for the Production and Exchange of Natallia 14 Bazgadze’s Confidential JPMorgan Chase Bank, N.A. Information and Records (the 15 “Stipulation”) in the above-captioned action. I understand its terms and agree to be fully 16 17 18 19 bound by them, and I hereby submit to the jurisdiction of the United States District Court for the District of Nevada for purposes of enforcement of the Stipulation. I further agree not to disclose or use any Confidential Discovery Material (as defined in the Stipulation) for purposes other than those permitted under the Stipulation. 20 21 _________________________________________ Signature 22 _________________________________________ Signature 23 24 _________________________________________ Signature 25 26 27 28 _____________________________ Date 16
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