Florence v. Cenlar Federal Savings and Loan et al, No. 2:2016cv00587 - Document 30 (D. Nev. 2016)
Court Description: STIPULATED PROTECTIVE ORDER Granting, as amended, 28 Stipulation for Protective Order. Signed by Magistrate Judge Nancy J. Koppe on 8/26/16. (Copies have been distributed pursuant to the NEF - MMM)
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Florence v. Cenlar Federal Savings and Loan et al Doc. 30 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 1 of 13 1 J Christopher Jorgensen (SBN 5382) E-mail: cjorgensen@lrrc.com 2 LEWIS ROCA ROTHGERBER CHRISTIE LLP 3993 Howard Hughes Pkwy, Suite 600 3 Las Vegas, NV 89169 Tel: 702.949.8200 4 Fax: 702.949.8398 5 Attorneys for Defendant New Penn Financial, LLC dba 6 Shellpoint Mortgage Servicing 7 UNITED STATE DISTRICT COURT 8 DISTRICT OF NEVADA 9 Case No.: 2:16-cv-00587-GMN-NJK 11 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 10 REGINA M. FLORENCE, STIPULATED [PROPOSED] PROTECTIVE ORDER Plaintiff, 12 vs. 13 CENLAR FEDERAL SAVINGS & LOAN; SELECT PORTFOLIO SERVICING; 14 SHELLPOINT MORTGAGE SERVICING; AS AMENDED EXPERIAN INFORMATION SOLUTIONS, 15 INC., 16 Defendants. 17 18 19 Pursuant to Federal Rule of Civil Procedure 26(c), Plaintiff Regina M. Florence 20 (“Plaintiff”), and Defendant New Penn Financial, LLC dba Shellpoint Mortgage 21 Servicing (“Defendant”), by and through their respective counsel of record, hereby 22 submit this stipulated proposed protective order and request entry thereof. 23 I. GENERAL PROVISIONS 24 A. PURPOSES AND LIMITATIONS 25 Discovery in this action may involve production of confidential, proprietary, or 26 private information for which special protection from public disclosure and from use for 27 any purpose other than prosecuting this litigation may be warranted. Such confidential 28 materials and information consist of, among other things, confidential business or Dockets.Justia.com Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 2 of 13 1 financial information, information regarding confidential business practices, or 2 information implicating privacy rights, information otherwise generally unavailable to 3 the public, or which may be privileged or otherwise protected from disclosure under 4 state or federal statutes, court rules, case decisions, or common law. 5 To expedite the flow of information, to facilitate the prompt resolution of 6 disputes over confidentiality of discovery materials, to adequately protect information 7 the parties are entitled to keep confidential, to ensure that the parties are permitted 8 reasonably necessary uses of such material in preparation for and in the conduct of trial, 9 to address their handling at the end of the litigation, and serve the ends of justice, a 10 protective order for such information is justified in this matter. It is the intent of the 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 parties that information will not be designated as confidential for tactical reasons and 12 that nothing be so designated without a good faith belief that it has been maintained in a 13 confidential, non-public manner, and there is good cause why it should not be part of the 14 public record of this case. 15 Accordingly, the parties hereby stipulate to and petition the Court to enter the 16 following Stipulated Protective Order. The parties acknowledge that this Order does not 17 confer blanket protections on all disclosures or responses to discovery and that the 18 protection it affords from public disclosure and use extends only to the limited 19 information or items that are entitled to confidential treatment under the applicable legal 20 principles. 21 22 II. 2.1. DEFINITIONS Action: This pending federal lawsuit, captioned as Regina M. Florence 23 v. Cenlar Federal Savings & Loan, et al., Case Number 2:16-cv-00587-GMN-NJK. 24 2.2. Challenging Party: A Party or Non-Party that challenges the 25 designation of information or items under this Order. 26 2.3. “CONFIDENTIAL” Information or Items: Information (regardless of 27 how it is generated, stored or maintained) or tangible things that qualify for protection 28 under Federal Rule of Civil Procedure 26(c), and as specified above in the Purpose and 2 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 3 of 13 1 Limitations section. 2 2.4. Counsel: Outside Counsel of Record and In-House Counsel (as well as 3 their support staff). 4 2.5. Designating Party: A Party or Non-Party that designates information or 5 items that it produces in disclosures or in responses to discovery as 6 “CONFIDENTIAL.” 7 2.6. Disclosure or Discovery Material: All items or information, regardless 8 of the medium or manner in which it is generated, stored, or maintained (including, 9 among other things, testimony, transcripts, and tangible things), that are produced or 10 generated in disclosures or responses to discovery in this matter. 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 2.7. Expert: A person with specialized knowledge or experience in a matter 12 pertinent to the litigation who has been retained by a Party or its counsel to serve as an 13 expert witness or as a consultant in this Action. 14 2.8. In-House Counsel: Attorneys who are employees of a party to this 15 Action. In-House Counsel does not include Outside Counsel of Record or any other 16 outside counsel. 17 2.9. Non-Party: Any natural person, partnership, corporation, association, or 18 other legal entity not named as a Party to this action. 19 2.10. Outside Counsel of Record: Attorneys who are not employees of a 20 party to this Action but are retained to represent or advise a party to this Action and have 21 appeared in this Action on behalf of that party or are affiliated with a law firm that has 22 appeared on behalf of that party, including support staff. 23 2.11. Party: Any party to this Action, including all of its officers, directors, 24 employees, consultants, retained experts, and Outside Counsel of Record (and their 25 support staffs). 26 2.12. Producing Party: A Party or Non-Party that produces Disclosure or 27 Discovery Material in this Action. 28 / / / 3 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 4 of 13 1 2.13. Professional Vendors: Persons or entities that provide litigation support 2 services (e.g., photocopying, videotaping, translating, preparing exhibits or 3 demonstrations, and organizing, storing, or retrieving data in any form or medium) and 4 their employees and subcontractors. 5 2.14. Protected Material: Any Disclosure or Discovery Material that is 6 designated as “CONFIDENTIAL.” 7 2.15. Receiving Party: A Party that receives Disclosure or Discovery Material 8 from a Producing Party. 9 10 III. SCOPE The protections conferred by this Stipulation and Order cover not only Protected 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 Material (as defined above), but also (1) any information copied or extracted from 12 Protected Material; (2) all copies, excerpts, summaries, or compilations of Protected 13 Material; and (3) any testimony, conversations, or presentations by Parties or their 14 Counsel that might reveal Protected Material. 15 Any use of Protected Material at trial shall be governed by the orders of the trial 16 judge. This Order does not govern the use of Protected Material at trial. 17 18 IV. DURATION Once a case proceeds to trial, all of the information to be introduced that was 19 previously designated as CONFIDENTIAL or maintained pursuant to this protective 20 order, and which is used or introduced as an exhibit at trial, becomes public and will be 21 presumptively available to all members of the public, including the press, unless 22 compelling reasons supported by specific factual findings to proceed otherwise are made 23 to the trial judge in advance of the trial. See Kamakana v. City and County of Honolulu, 24 447 F.3d 1172, 1180-81 (9th Cir. 2006) (distinguishing “good cause” showing for 25 sealing documents produced in discovery from “compelling reasons” standard when 26 merits-related documents are part of court record). Accordingly, the terms of this 27 protective order do not extend beyond the commencement of the trial, with two 28 exceptions: 4 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 5 of 13 1 1. Any information designated as “CONFIDENTIAL” that is not 2 used or introduced as an exhibit at trial shall remain protected under this Order and be 3 subject to final disposition as set forth under Section 12 (FINAL DISPOSITION). 4 2. Should resolution be reached prior to a trial, the terms of the 5 protective order extend up to final disposition of the Action. 6 7 V. 5.1. DESIGNATING PROTECTED MATERIAL Exercise of Restraint and Care in Designating Material for 8 Protection. Each Party or Non-Party that designates information or items for protection 9 under this Order must take care to limit any such designation to specific material that 10 qualifies under the appropriate standards. The Designating Party must designate for 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 protection only those parts of material, documents, items, or oral or written 12 communications that qualify so that other portions of the material, documents, items, or 13 communications for which protection is not warranted are not swept unjustifiably within 14 the ambit of this Order. 15 Mass, indiscriminate, or routinized designations are prohibited. Designations that 16 are shown to be clearly unjustified or that have been made for an improper purpose (e.g., 17 to unnecessarily encumber the case development process or to impose unnecessary 18 expenses and burdens on other parties) may expose the Designating Party to sanctions. 19 If it comes to a Designating Party’s attention that information or items that it 20 designated for protection do not qualify for protection, and the Designating Party agrees 21 or the Court orders otherwise, that Designating Party must promptly notify all other 22 Parties that it is withdrawing the inapplicable designation. 23 5.2. Manner and Timing of Designations. Except as otherwise provided in 24 this Order (see, e.g., second paragraph of section 5.2(a), below), or as otherwise 25 stipulated or ordered, Disclosure or Discovery Material that qualifies for protection 26 under this Order must be clearly so designated before the material is disclosed or 27 produced. Designation in conformity with this Order requires: 28 / / / 5 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 6 of 13 1 (a) for information in documentary form (e.g., paper or electronic 2 documents, but excluding transcripts of depositions or other pretrial or trial 3 proceedings), that the Producing Party affix, at a minimum, the legend 4 “CONFIDENTIAL” (hereinafter “CONFIDENTIAL legend”), to each page that 5 contains protected material. If only a portion or portions of the material on a page 6 qualifies for protection, the Producing Party also must clearly identify the protected 7 portion(s) (e.g., by making appropriate markings in the margins) to the extent possible. 8 A Party or Non-Party that makes original documents available for 9 inspection need not designate them for protection until after the inspecting Party has 10 indicated which documents it would like copied and produced. During the inspection 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 and before the designation, all of the material made available for inspection shall be 12 deemed “CONFIDENTIAL.” After the inspecting Party has identified the documents it 13 wants copied and produced, the Producing Party must determine which documents, or 14 portions thereof, qualify for protection under this Order. Then, before producing the 15 specified documents, the Producing Party must affix the “CONFIDENTIAL legend” to 16 each page that contains Protected Material. If only a portion or portions of the material 17 on a page qualifies for protection, the Producing Party also must clearly identify the 18 protected portion(s) (e.g., by making appropriate markings in the margins). 19 (b) for testimony given in depositions that the Designating Party 20 identifies the Disclosure or Discovery Material on the record, before the close of the 21 deposition all protected testimony. In the alternative, the Designating Party may 22 designate the entirety of the testimony given at the deposition, as well as exhibits, as 23 “CONFIDENTIAL” prior to conclusion of the deposition with the right to identify more 24 specific portions of the testimony as to which protection is sought within 30 days 25 following receipt of the deposition transcript. Where portions of the testimony are 26 designated for protection, the transcript pages containing Disclosure or Discovery 27 Material may be separately bound by the court reporter with the legend 28 “CONFIDENTIAL” at the top of each such page. 6 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 7 of 13 1 (c) for information produced in some form other than documentary 2 and for any other tangible items, that the Producing Party affix in a prominent place on 3 the exterior of the container or containers in which the information is stored the legend 4 “CONFIDENTIAL.” If only a portion or portions of the information warrants 5 protection, the Producing Party, to the extent practicable, shall identify the protected 6 portion(s). 7 5.3. Inadvertent Failures to Designate. If timely corrected, an inadvertent 8 failure to designate qualified information or items does not, standing alone, waive the 9 Designating Party’s right to secure protection under this Order for such material. Upon 10 timely correction of a designation, the Receiving Party must make reasonable efforts to 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 assure that the material is treated in accordance with the provisions of this Order. 12 13 VI. 6.1. CHALLENGING CONFIDENTIALITY DESIGNATIONS Timing of Challenges. Any Party or Non-Party may challenge a 14 designation of confidentiality at any time that is consistent with the Court’s Scheduling 15 Order. 16 6.2. Meet and Confer. The Challenging Party shall initiate the dispute 17 resolution process under Local Civil Rule 26-7. Any discovery motion must strictly 18 comply with the procedures set forth in Local Civil Rules 26-7 and 26-8. 19 6.3. Burden. The burden of persuasion in any such challenge proceeding 20 shall be on the Designating Party. Frivolous challenges, and those made for an improper 21 purpose (e.g., to harass or impose unnecessary expenses and burdens on other parties) 22 may expose the Challenging Party to sanctions. Unless the Designating Party has 23 waived or withdrawn the confidentiality designation, all parties shall continue to afford 24 the material in question the level of protection to which it is entitled under the Producing 25 Party’s designation until the Court rules on the challenge. 26 27 VII. 7.1. ACCESS TO AND USE OF PROTECTED MATERIAL Basic Principles. A Receiving Party may use Protected Material that is 28 disclosed or produced by another Party or by a Non-Party in connection with this Action 7 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 8 of 13 1 only for prosecuting, defending, or attempting to settle this Action. 2 (a) Such Protected Material may be disclosed only to the categories of 3 persons and under the conditions described in this Order. 4 (b) When the Action has been terminated, a Receiving Party must comply 5 with the provisions of Section 12 below (FINAL DISPOSITION). 6 (c) Protected Material must be stored and maintained by a Receiving Party at 7 a location and in a secure manner that ensures that access is limited to the persons 8 authorized under this Order. 9 7.2. Disclosure of “CONFIDENTIAL” Information or Items. Unless 10 otherwise ordered by the Court or permitted in writing by the Designating Party, a 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 Receiving Party may disclose any information or item designated “CONFIDENTIAL” 12 only to: 13 (a) the Receiving Party’s Outside Counsel of Record in this Action, as 14 well as employees of said Outside Counsel of Record to whom it is reasonably necessary 15 to disclose the information for this Action; 16 (b) the officers, directors, and employees (including In-House Counsel) 17 of the Receiving Party to whom disclosure is reasonably necessary for this Action; 18 (c) Experts (as defined in this Order) of any Party to whom disclosure is 19 reasonably necessary for this Action and who have signed the “Acknowledgment and 20 Agreement to Be Bound” (Exhibit A); 21 (d) the Court and its personnel; 22 (e) court reporters and their staff; 23 (f) professional jury or trial consultants, mock jurors, and Professional 24 Vendors to whom disclosure is reasonably necessary for this Action and who have 25 signed the “Acknowledgment and Agreement to Be Bound” (Exhibit A); 26 (g) the author or recipient of a document containing the information or a 27 custodian or other person who otherwise possessed or knew the information; 28 (h) during their depositions, witnesses, and attorneys for witnesses, in the 8 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 9 of 13 1 Action to whom disclosure is reasonably necessary provided: (1) the deposing party 2 requests that the witness sign the form attached as Exhibit 1 hereto; and (2) they will not 3 be permitted to keep any confidential information unless they sign the 4 “Acknowledgment and Agreement to Be Bound” (Exhibit A), unless otherwise agreed 5 by the Designating Party or ordered by the Court. Pages of transcribed deposition 6 testimony or exhibits to depositions that reveal Protected Material may be separately 7 bound by the court reporter and may not be disclosed to anyone except as permitted 8 under this Stipulated Protective Order; and 9 (i) any mediator or settlement officer, and their supporting personnel, 10 mutually agreed upon by any of the parties engaged in settlement discussions. 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 VIII. PROTECTED MATERIAL SUBPOENAED OR ORDERED 12 13 PRODUCED IN OTHER LITIGATION 1. If a Party is served with a subpoena or a court order issued in other 14 litigation that compels disclosure of any information or items designated in this Action 15 as “CONFIDENTIAL,” that Party must: 16 (a) promptly notify in writing the Designating Party. Such 17 notification shall include a copy of the subpoena or court order; 18 (b) promptly notify in writing the party who caused the subpoena or 19 order to issue in the other litigation that some or all of the material covered by the 20 subpoena or order is subject to this Protective Order. Such notification shall include a 21 copy of this Stipulated Protective Order; and 22 (c) cooperate with respect to all reasonable procedures sought to be 23 pursued by the Designating Party whose Protected Material may be affected. 24 2. If the Designating Party timely seeks a protective order, the Party served 25 with the subpoena or court order shall not produce any information designated in this 26 action as “CONFIDENTIAL” before a determination by the court from which the 27 subpoena or order issued, unless the Party has obtained the Designating Party’s 28 permission. The Designating Party shall bear the burden and expense of seeking 9 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 10 of 13 1 protection in that court of its confidential material and nothing in these provisions should 2 be construed as authorizing or encouraging a Receiving Party in this Action to disobey a 3 lawful directive from another court. 4 IX. 5 UNAUTHORIZED DISCLOSURE OF PROTECTED MATERIAL If a Receiving Party learns that, by inadvertence or otherwise, it has disclosed 6 Protected Material to any person or in any circumstance not authorized under this 7 Stipulated Protective Order, the Receiving Party must immediately (a) notify in writing 8 the Designating Party of the unauthorized disclosures, (b) use its best efforts to retrieve 9 all unauthorized copies of the Protected Material, (c) inform the person or persons to 10 whom unauthorized disclosures were made of all the terms of this Order, and (d) request 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 such person or persons to execute the “Acknowledgment and Agreement to Be Bound” 12 that is attached hereto as Exhibit A. 13 X. INADVERTENT PRODUCTION OF PRIVILEGED OR OTHERWISE 14 15 PROTECTED MATERIAL When a Producing Party gives notice to Receiving Parties that certain 16 inadvertently produced material is subject to a claim of privilege or other protection, the 17 obligations of the Receiving Parties are those set forth in Federal Rule of Civil 18 Procedure 26(b)(5)(B). This provision is not intended to modify whatever procedure 19 may be established in an e-discovery order that provides for production without prior 20 privilege review. Pursuant to Federal Rule of Evidence 502(d) and (e), insofar as the 21 parties reach an agreement on the effect of disclosure of a communication or information 22 covered by the attorney-client privilege or work product protection, the parties may 23 incorporate their agreement in the stipulated protective order submitted to the Court. 24 25 XI. 11.1. MISCELLANEOUS Right to Further Relief. Nothing in this Order abridges the right of any 26 person to seek its modification by the Court in the future. 27 11.2. Right to Assert Other Objections. By stipulating to the entry of this 28 Protective Order, no Party waives any right it otherwise would have to object to 10 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 11 of 13 1 disclosing or producing any information or item on any ground. Similarly, no Party 2 waives any right to object on any ground to use in evidence of any of the material 3 covered by this Protective Order. 4 11.3. Filing Protected Material. A Party that seeks to file under seal any 5 Protected Material must comply with Local Civil Rule 10-5. Protected Material may See order issued concurrently herewith 6 only be filed under seal pursuant to a court order authorizing the sealing of the specific 7 Protected Material at issue. If a Party’s request to file Protected Material under seal is 8 denied by the Court, then the Receiving Party may file the information in the public 9 record unless otherwise instructed by the Court. 10 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 XII. FINAL DISPOSITION After the final disposition of this Action, within 60 days of a written request by 12 the Designating Party, each Receiving Party must return all Protected Material to the 13 Producing Party or destroy such material. As used in this subdivision, “all Protected 14 Material” includes all copies, abstracts, compilations, summaries, and any other format 15 reproducing or capturing any of the Protected Material. Whether the Protected Material 16 is returned or destroyed, the Receiving Party must submit a written certification to the 17 Producing Party (and, if not the same person or entity, to the Designating Party) by the 18 60 day deadline that (1) identifies (by category, where appropriate) all the Protected 19 Material that was returned or destroyed and (2) affirms that the Receiving Party has not 20 retained any copies, abstracts, compilations, summaries or any other format reproducing 21 or capturing any of the Protected Material. Notwithstanding this provision, Counsel are 22 entitled to retain an archival copy of all pleadings, motion papers, trial, deposition, and 23 hearing transcripts, legal memoranda, correspondence, deposition and trial exhibits, 24 expert reports, attorney work product, and consultant and expert work product, even if 25 such materials contain Protected Material. Any such archival copies that contain or 26 constitute Protected Material remain subject to this Protective Order as set forth in 27 Section 4 (DURATION). 28 / / / 11 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 12 of 13 1 2 XIII. VIOLATION Any violation of this Order may be punished by appropriate measures including, 3 without limitation, contempt proceedings and/or monetary sanctions. 4 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. 5 DATED: August 25, 2016. 6 HAINES & KRIEGER, LLC 7 By /s/ Jennifer Isso David H. Krieger Jennifer Isso HAINES & KRIEGER, LLC 8985 S. Eastern Avenue, Suite 350 Henderson, Nevada 89123 8 9 10 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 12 DATED: August 25, 2016. 13 14 15 16 LEWIS ROCA ROTHGERBER CHRISTIE LLP By /s/ J Christopher Jorgensen J Christopher Jorgensen 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, Nevada 89169 17 18 19 ORDER FOR GOOD CAUSE SHOWN, IT IS SO ORDERED. 20 21 ____________________________ Hon. Gloria M. Navarro United States Magistrate Judge 22 August 26, 2016 DATED: _____________________ 23 24 25 26 27 28 12 Case 2:16-cv-00587-GMN-NJK Document 28 Filed 08/25/16 Page 13 of 13 1 EXHIBIT A 2 ACKNOWLEDGMENT AND AGREEMENT TO BE BOUND 3 I, _____________________________________ [print or type full name], of 4 _______________________________________________________________________ 5 [print or type full address], declare under penalty of perjury under the laws of the United 6 States that I have read in its entirety and understand the Stipulated Protective Order that 7 was issued by the United States District Court for the District of Nevada on 8 __________________ [date] in the case of Regina M. Florence v. Cenlar Federal 9 Savings & Loan, et al., Case Number 2:16-cv-00587-GMN-NJK. I agree to comply 10 with and to be bound by all the terms of this Stipulated Protective Order and I 3993 Howard Hughes Pkwy, Suite 600 Las Vegas, NV 89169-5996 11 understand and acknowledge that failure to so comply could expose me to sanctions and 12 punishment in the nature of contempt. I solemnly promise that I will not disclose in any 13 manner any information or item that is subject to this Stipulated Protective Order to any 14 person or entity except in strict compliance with the provisions of this Order. 15 I further agree to submit to the jurisdiction of the United States District Court for 16 the District of Nevada for the purpose of enforcing the terms of this Stipulated 17 Protective Order, even if such enforcement proceedings occur after termination of this 18 action. I hereby appoint _______________________________ [print or type full name] 19 of _____________________________________________________________________ 20 [print or type full address and telephone number] as my agent for service of process in 21 connection with this action or any proceedings related to enforcement of this Stipulated 22 Protective Order. 23 24 Date: ______________________________________ 25 City and State where sworn and signed: _________________________________ 26 Printed name: _______________________________ 27 Signature: __________________________________ 28 13
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