U.S. Bank National Association v. North American Title Insurance Company, No. 2:2019cv01154 - Document 14 (D. Nev. 2020)
Court Description: PROTECTIVE ORDER Granting 13 Stipulated Protective Order. Signed by Magistrate Judge Elayna J. Youchah on 1/14/2020. (Copies have been distributed pursuant to the NEF - SLD)
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U.S. Bank National Association v. North American Title Insurance Company 1 2 3 4 5 6 7 Doc. 14 AARON R. MAURICE, ESQ. Nevada Bar No. 006412 BRITTANY WOOD, ESQ. Nevada Bar No. 007562 ELIZABETH E. ARONSON, ESQ. Nevada Bar No. 014472 KOLESAR & LEATHAM 400 South Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Telephone: (702) 362-7800 Facsimile: (702) 362-9472 E-Mail: amaurice@klnevada.com bwood@klnevada.com earonson@klnevada.com 8 9 Attorneys for Defendant, NORTH AMERICAN TITLE INSURANCE COMPANY 10 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 *** 13 14 15 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR GREENPOINT MORTGAGE FUNDING TRUST MORTGAGE PASS-THROUGH CERTIFICATES, SERIES 2006-AR7, 16 Plaintiff, CASE NO. 2:19-cv-01154-RFB-EJY STIPULATED PROTECTIVE ORDER 17 vs. 18 19 NORTH AMERICAN TITLE INSURANCE COMPANY, 20 Defendant. 21 22 Subject to the approval of the Court, U.S. Bank National Association, as Trustee for 23 Greenpoint Mortgage Funding Trust Mortgage Pass-Through Certificates, Series 2006-AR7 (U.S. 24 Bank) and North American Title Insurance Company (NATIC), by and through their attorneys of 25 record, stipulate to the following Protective Order: 26 To expedite the flow of discovery, facilitate the prompt resolution of disputes over 27 confidentiality, adequately protect material claimed to be confidential, and ensure protection is 28 afforded only to material so designated, it is, pursuant to the Court's authority under Federal Rules 3299426 (10661-7) Page 1 of 13 Dockets.Justia.com 1 of Civil Procedure 26(c), ORDERED this Protective Order shall govern the disclosure, handling 2 and disposition of documents in this litigation as follows: 1. 3 1.1 4 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 This Protective Order shall govern any document, information or other 5 material that is designated as containing "Confidential Information" as defined herein, and is 6 produced in connection with this litigation by any person or entity (the "producing party"), whether 7 in response to a discovery request, subpoena or otherwise, to any other person or entity (the 8 "receiving party") regardless of whether the person or entity producing or receiving such 9 information is a party to this litigation. 1.2 10 KOLESAR & LEATHAM Application. The party who asserts that particular information should be treated as 11 Confidential Information under this Protective Order has the burden of proof to establish that the 12 information or document is entitled to such protection. 2. 13 Definitions. 2.1 14 Confidential Information. "Confidential Information" shall mean and 15 include, without limitation, any non-public information that concerns or relates to the following 16 areas: confidential proprietary information, trade secrets, practices and procedures, personal 17 financial information, commercial, financial, pricing, budgeting, and/or accounting information, 18 information about existing and potential customers, marketing studies, performance projections, 19 business strategies, decisions and/or negotiations, personnel compensation, evaluations and other 20 employment information, and confidential proprietary information about affiliates, parents, 21 subsidiaries and third-parties with whom the parties to this action have or have had business 22 relationships. 2.2 23 Documents. As used herein, the term "documents" includes all writings, 24 records, 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 Federal Rules of Civil Procedure. 27 /// 28 /// 3299426 (10661-7) Page 2 of 13 3. 1 3.1 2 to documents, other tangible things and information that the asserting party has a good faith belief 4 are 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. 3.2 Produced Documents. A party producing documents that it believes 7 constitute or contain Confidential Information shall state that the material is being produced under 8 this Protective Order by describing the documents or materials to be treated as confidential in 9 writing, by page or bates number wherever possible and/or shall produce copies bearing a label that 10 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 Good Faith Claims. Claims of confidentiality will be made only with respect 3 6 KOLESAR & LEATHAM Initial Designation. contains or includes language substantially identical to the following: CONFIDENTIAL 11 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 receiving 25 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 /// 3299426 (10661-7) Page 3 of 13 3.3 1 2 discovery 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. 3.4 5 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 Inspection of Documents. In the event a party elects to produce files and 6 records for 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 KOLESAR & LEATHAM Interrogatory Answers. If a party answering an interrogatory or other accordance with subparagraph 3.2 at the time the copies are produced. 3.5 11 Deposition Transcripts. The party asserting confidentiality shall state on the 12 record the portions it deems confidential. The failure to designate testimony on the record as 13 confidential shall be a waiver unless the designating party notifies all other parties and files a motion 14 to designate the testimony as confidential within 5 days of the notification. 3.6 15 Inadvertent Failure to Designate. Inadvertent failure to identify documents 16 or things as "Confidential" pursuant to this Protective Order shall not constitute a waiver of any 17 otherwise valid claim for protection, provided that the provisions of this paragraph are satisfied. If 18 the designating party discovers that information should have but was not designated "Confidential" 19 or 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 required 24 by this Protective Order, and the receiving party(ies) shall promptly, and in no event more than 25 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 3299426 (10661-7) Page 4 of 13 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. 4.1 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 4 KOLESAR & LEATHAM Designations by Another Party. Notification of Designation. If a party other than the producing party believes 5 that a producing party has produced a document that contains or constitutes Confidential 6 Information of the non-producing party, the non-producing party may designate the document as 7 Confidential Information by so notifying all parties in writing within fourteen (14) days of service 8 of the document. 9 4.2 Return of Documents; Non-disclosure. Whenever a party other than the 10 producing party designates a document produced by a producing party as Confidential Information 11 in 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 document 16 to any person, other than the persons authorized to receive Confidential Information under 17 subparagraph 7.1, until after the expiration of the fourteen (14) day designation period specified in 18 subparagraph 4.1. If during the fourteen (14) day designation period a party discloses a produced 19 document to a person authorized to receive Confidential Information under subparagraph 7.1, and 20 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 designating 24 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 3299426 (10661-7) Page 5 of 13 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM 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 rules 19 that a designation should not be maintained as to a particular document, the producing party shall, 20 upon written request by a party, provide that party a copy of that document without the designation 21 described in subparagraph 3.2. 22 If an objecting party elects not to make such a motion with respect to documents within twenty 23 one (21) days after the conference, information or other materials to which an objection has been 24 made, the objection shall be deemed withdrawn. The designating party shall have twenty one (21) 25 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 /// 3299426 (10661-7) Page 6 of 13 1 6. Custody. All Confidential Information and any and all copies, extracts and 2 summaries thereof, including memoranda relating thereto, shall be retained by the receiving party 3 in the custody of counsel of record, or by persons to whom disclosure is authorized under 4 subparagraph 7.1. 5 7. 7.1 6 7 Handling Prior to Trial. Authorized Disclosures. Confidential Information shall be disclosed by the receiving party only to the following persons: a. 8 clerks, paralegals, and secretarial personnel; 9 b. 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 10 KOLESAR & LEATHAM Counsel for the parties in this litigation, including their associates, Qualified persons taking testimony in this litigation involving such 11 Confidential Information, and necessary stenographic, videotape and 12 clerical personnel; c. 13 Experts and their staff who are retained by counsel as expert witnesses for a party in this litigation; 14 d. 15 Experts and their staff who are consulted by counsel for a party in this litigation; 16 e. 17 Parties to this litigation, limited to the named party and, if that party is 18 a corporate entity, a limited number of employees of the corporate entity 19 and its insurers; f. 20 Designated in-house counsel and a limited number of assistants, administrative or otherwise; 21 g. 22 Outside vendors employed by counsel for copying, scanning and general handling of documents; 23 h. 24 Any person of whom testimony is taken regarding the Confidential 25 Information, except that such person may only be shown Confidential 26 Information during his/her testimony, and may not retain a copy of such 27 Confidential Information; and 28 3299426 (10661-7) Page 7 of 13 i. 1 filing materials under seal. 2 Such disclosures are authorized only to the extent necessary to investigate, prosecute, or 3 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM 4 This Court and this Court’s staff, subject to the Court’s processes for defend the litigation. 5 Confidential Information may not be disclosed to persons under subparagraphs (c) or (d) until 6 the receiving party has obtained a written acknowledgment from the person receiving Confidential 7 Information, in the form of the Declaration attached hereto as Exhibit A, that he or she has received 8 a copy of this Protective Order and has agreed to be bound by it. A party who discloses Confidential 9 Information in accordance with subparagraph 7.1 shall retain the written acknowledgment from each 10 person receiving Confidential Information, shall maintain a list of all persons to whom a receiving 11 party has disclosed Confidential Information and identify what documents have been disclosed, and 12 shall furnish the written acknowledgments and disclosure list to opposing counsel as follows: (i) for 13 a person under subparagraph (c), within thirty (30) days after the person signs the Declaration; and 14 (ii) for a person under subparagraph (d), within thirty (30) days after the matter is finally concluded. 15 Disclosure of Confidential Information to this Court, including judicial staff, shall be made in 16 accordance with subparagraph 7.4 of this Protective Order. 7.2 17 Unauthorized Disclosures. All persons receiving Confidential Information 18 under the terms of this Protective Order are under the jurisdiction of the state courts and U.S. federal 19 courts located in Nevada for all matters arising from the improper disclosure or use of such 20 information. If Confidential Information is disclosed to any person other than in the manner 21 authorized by this Protective Order, the party or person responsible for the disclosure, and any other 22 party or person who is subject to this Protective Order and learns of such disclosure, shall 23 immediately bring such disclosure to the attention of the designating party. Without prejudice to 24 other rights and remedies of the designating party, the responsible party or person shall make every 25 effort to obtain and return the Confidential Information and to prevent further disclosure on its own 26 part or on the part of the person who was the unauthorized recipient of such information. 27 /// 28 /// 3299426 (10661-7) Page 8 of 13 7.3 1 2 the Court prior to trial, the proposed filing shall be accompanied by a motion to file the Confidential 3 Information under seal that complies with Local Rule 10-5(b) and a proposed order, and the 4 application and proposed order shall be directed to the judge to whom the Confidential Information 5 is directed. This provision is applicable to briefs, memoranda, and other filings which quote, 6 summarize, or describe Confidential Information. 7 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 8. Care in Storage. Any person in possession of Confidential Information produced by 8 another party shall exercise reasonable and appropriate care with regard to the storage, custody, 9 copying, and use of such information to ensure that the confidential and sensitive nature of same is 10 KOLESAR & LEATHAM Court Filings. In the event any Confidential Information must be filed with 11 maintained. 9. Handling During Trial. Confidential Information that is subject to this Order may 12 be marked and used as trial exhibits by either party, subject to terms and conditions as imposed by 13 the Court upon application by any party. 14 10. No Implied Waivers. This Protective Order shall not be interpreted as a waiver of 15 the right to object, under applicable law, to the furnishing of information in response to discovery 16 requests or to object to a requested inspection of documents or facilities. Parties producing 17 Confidential Information in this litigation are doing so only pursuant to the terms of this Protective 18 Order. The taking of any action in accordance with the provisions of this Protective Order shall not 19 be interpreted as a waiver of any claim or position or defense in this action, or any other actions. 20 11. No Admission. The designation of any item as Confidential Information shall not be 21 construed as an admission that such material, or any testimony concerning such material, would be 22 admissible in evidence in this litigation or in any other proceeding. 23 12. Inadvertent Disclosure. Nothing in this Protective Order abridges applicable law 24 concerning inadvertent disclosure of a document that the Disclosing Party believes contains 25 attorney-client communications, attorney work product, or otherwise privileged information. If a 26 party inadvertently discloses documents or information subject to a claim of privilege or work 27 product protection, such disclosure will not waive otherwise applicable claims of privilege or work 28 product protection under applicable law. Upon discovery by the Receiving Party, or receipt of 3299426 (10661-7) Page 9 of 13 1 written notice from the Disclosing Party identifying privileged or protected Documents that were 2 inadvertently produced, the receiving party shall within seven (7) business days either: (a) return or 3 certify the destruction of all such documents, all copies, and any work product or portions of any 4 work product containing or reflecting the contents of the subject materials; or (b) after attempting 5 to resolve any dispute with opposing counsel informally, file a motion to challenge the assertion of 6 privilege and tender the subject documents for in camera review with the motion. The moving party 7 shall do nothing to compromise the privilege claim until the Court rules on said motion and the 8 opportunity for appellate review is exhausted or the issue is otherwise resolved. 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM 9 13. Parties’ Own Documents. This Protective Order shall in no way restrict the parties 10 in their use of their own documents and information, and nothing in this Protective Order shall 11 preclude any party from voluntarily disclosing its own documents or information to any party or 12 nonparty. 13 14. Motion by Third Party to Compel Production of Confidential Information. If 14 any third party subpoenas Confidential Information from a party to this action or moves to compel 15 a party to this action to produce any such information, such party shall immediately notify the parties 16 who originally produced and/or designated such information that a subpoena has been served or a 17 motion has been made in order to allow the parties who originally produced and/or designated such 18 information the opportunity to seek a protective order or oppose the motion or application. If, within 19 thirty (30) days after receiving notice of a subpoena seeking Confidential Information from a 20 receiving party, the party who originally produced and/or designated such information fails to move 21 for a protective order, the party subject to the subpoena may produce said information. In addition, 22 if a party is ordered to produce Confidential Information covered by this Protective Order, then 23 notice and, if available, a copy of the order compelling disclosure shall immediately be given the 24 parties who originally produced and/or designated such information. Nothing in this Protective 25 Order shall be construed as requiring the party who is ordered to produce such Confidential 26 Information to challenge or appeal any order requiring the production of such information or to 27 subject himself/herself to any penalty for non-compliance with any legal process or seek any relief 28 from the Court. 3299426 (10661-7) Page 10 of 13 15. 1 2 diminish any pre-existing contractual, statutory, or other legal obligations or rights of any party with 3 respect to Confidential Information. 16. 4 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 Modification. In the event any party hereto seeks a Court order to modify the terms 5 of this Protective Order, or seeks a protective order which incorporates the terms and conditions of 6 this Protective Order said party shall make such request by written stipulation or noticed motion to 7 all parties that must be served and filed in accordance with local court rules. 17. 8 KOLESAR & LEATHAM No Effect on Other Rights. This Protective Order shall in no way abrogate or Handling Upon Conclusion of Litigation. All parties, counsel, and persons to 9 whom disclosure was made agree to return all Confidential Information to the designating party 10 within thirty (30) days of the conclusion of litigation between the parties, including final appellate 11 action or the expiration of time to appeal or seek further review. In addition, counsel shall certify in 12 writing that all such Confidential Information have been returned. Counsel for each party also shall 13 contact each person to whom that party has provided a copy of any Confidential Information and 14 request the documents be returned. In lieu of returning Confidential Information, the person or party 15 in possession of such information may elect to destroy it. If the person or party in possession of 16 Confidential Information elects to destroy it rather than return it, that person or party must notify 17 the designating party in writing of the destruction of the information within ninety (90) days of the 18 conclusion of litigation between the parties, including final appellate action or the expiration of time 19 to appeal or seek further review. 20 /// 21 22 /// 23 24 /// 25 26 /// 27 28 /// 3299426 (10661-7) Page 11 of 13 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 3 until a Designating Party otherwise in writing or a court order otherwise directs. 4 DATED this 13th day of January, 2020. 5 6 7 8 9 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM 10 11 12 WRIGHT, FINLAY & ZAK. LLP KOLESAR & LEATHAM /s/ Lindsay D. Robbins LINDSAY D. ROBBINS, ESQ. Nevada Bar No. 13474 7785 W. Sahara Avenue, Suite 200 Las Vegas, Nevada 89117 /s/Brittany Wood AARON R. MAURICE, ESQ. Nevada Bar No. 6412 BRITTANY WOOD, ESQ. Nevada Bar No. 7562 ELIZABETH E. ARONSON, ESQ. Nevada Bar No. 14472 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Attorneys for Plaintiff, U.S. Bank National Association, as Trustee For Greenpoint Mortgage Funding Trust Mortgage PassThrough Certificates, Series 2006-AR7 13 Attorneys for Defendant, North American Title Insurance Company 14 15 16 17 IT IS SO ORDERED. 18 _____________________________________ UNITED STATES MAGISTRATE JUDGE 19 20 January 14, 2020 DATED: _____________________________ 21 22 23 24 25 26 27 28 3299426 (10661-7) Page 12 of 13 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 4 I, ______________________, and read in its entirety and understand the Protective Order that was issued by the United States District Court, for the District of Nevada, on 5 6 400 S. Rampart Boulevard, Suite 400 Las Vegas, Nevada 89145 Tel: (702) 362-7800 / Fax: (702) 362-9472 KOLESAR & LEATHAM 7 ________________, 2020, in the case of U.S. Bank National Association, as Trustee for Greenpoint Mortgage Funding Trust Mortgage Pass-Through Certificates, Series 2006-AR7, Case 8 No.: 2:19-cv-01154-RFB-EJY. I agree to comply with and be bound by all terms of this Protective 9 Order and I understand and acknowledge that failure to so comply could expose me to sanctions 10 and punishment in the nature of contempt. I solemnly promise that I will not disclose in any 11 12 manner any information or item that is subject to this Protective Order to any person or entity except in strict compliance with this Protective Order. Further, I solemnly promise that I will not 13 14 15 offer to sell, advertise or publicize that I have obtained any protected material subject to this Protective Order. 16 At the conclusion of this matter, I will return all protected materials which came into my 17 possession or control to counsel for the party from whom I received the protected material, or I 18 will destroy those materials. I understand that any confidential information contained within any 19 summaries of protected material shall remain protected pursuant to the terms of this Order. 20 I further agree to submit to the jurisdiction of the United States District Court, for the 21 22 23 District of Nevada for the purpose of enforcing the terms of this Protective Order, even if such enforcement proceedings occur after termination of this action. 24 I certify under penalty of perjury that the foregoing is true and correct. 25 Date: ____________________________ 26 27 28 City and State where signed: ________________________________ Printed Name: ___________________________________________ Address: ________________________________________________ Signature: _______________________________________________ 3299426 (10661-7) Page 13 of 13
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