NewRez LLC dba Shellpoint Mortgage Servicing v. Joel A. Stokes and Sandra F. Stokes, as Trustees of the Jimijack Irrevocable Trust, No. 2:2020cv00946 - Document 15 (D. Nev. 2021)
Court Description: ORDER Granting 14 Stipulated Protective Order. Signed by Magistrate Judge Brenda Weksler on 1/11/2021. (Copies have been distributed pursuant to the NEF - JQC)
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NewRez LLC dba Shellpoint Mortgage Servicing v. Joel A. Stokes and ...the Jimijack Irrevocable Trust Doc. 15 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 1 of 12 1 2 3 4 5 6 7 8 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 9 ARIEL E. STERN, ESQ. Nevada Bar No. 8276 NATALIE L. WINSLOW, ESQ. Nevada Bar No. 12125 NICHOLAS E. BELAY, ESQ. Nevada Bar No. 15175 Akerman LLP 1635 Village Center Circle, Suite 200 Las Vegas, Nevada 89134 Telephone: (702) 634-5000 Facsimile: (702) 380-8572 Email: ariel.stern@akerman.com Email: natalie.winslow@akerman.com Email: nicholas.belay@akerman.com Attorneys for NewRez LLC dba Shellpoint Mortgage Servicing 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 14 NEWREZ LLC DBA MORTGAGE SERVICING, SHELLPOINT Plaintiff, 15 16 vs. 17 JOEL A. STOKES AND SANDRA F. STOKES, as trustees of the JIMIJACK IRREVOCABLE TRUST; DOE INDIVIDUALS I-X, inclusive, and ROE CORPORATIONS I-X, inclusive, 18 19 Case No.: 2:20-cv-00946-JCM-BNW STIPULATED PROTECTIVE ORDER Defendants. 20 21 Subject to the approval of the Court, NewRez LLC dba Shellpoint Mortgage Servicing 22 (Shellpoint) and Joel A. Stokes and Sandra F. Stokes, as Trustees of the Jimijack Irrevocable Trust 23 (Stokes), by and through their attorneys of record, stipulate to the following Protective Order: 24 To expedite the flow of discovery, facilitate the prompt resolution of disputes over 25 confidentiality, adequately protect material claimed to be confidential, and ensure protection is 26 afforded only to material so designated, it is, pursuant to the Court's authority under Federal Rules of 27 Civil Procedure 26(c), ORDERED this Protective Order shall govern the disclosure, handling and 28 disposition of documents in this litigation as follows: 55014460;1 Dockets.Justia.com Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 2 of 12 1 1. 2 1.1 that is designated as containing "Confidential Information" as defined herein, and is produced in 4 connection with this litigation by any person or entity (the "producing party"), whether in response to 5 a discovery request, subpoena or otherwise, to any other person or entity (the "receiving party") 6 regardless of whether the person or entity producing or receiving such information is a party to this 7 litigation. 9 10 AKERMAN LLP This Protective Order shall govern any document, information or other material 3 8 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Application. 11 1.2 The party who asserts that particular information should be treated as Confidential Information under this Protective Order has the burden of proof to establish that the information or document is entitled to such protection. 2. 12 Definitions. 2.1 Confidential Information. "Confidential Information" shall mean and include, 13 without limitation, any non-public information that concerns or relates to the following areas: 14 confidential proprietary information, trade secrets, practices and procedures, personal financial 15 information, commercial, financial, pricing, budgeting, and/or accounting information, information 16 about existing and potential customers, marketing studies, performance projections, business 17 strategies, decisions and/or negotiations, personnel compensation, evaluations and other employment 18 information, and confidential proprietary information about affiliates, parents, subsidiaries and third- 19 parties with whom the parties to this action have or have had business relationships. 20 2.2 Documents. As used herein, the term "documents" includes all writings, 21 records, files, drawings, graphs, charts, photographs, e-mails, video tapes, audio tapes, compact discs, 22 electronic messages, other data compilations from which information can be obtained and other 23 tangible things subject to production under the Federal Rules of Civil Procedure. 24 3. 25 Initial Designation. 3.1 Good Faith Claims. Claims of confidentiality will be made only with respect to 26 documents, other tangible things and information that the asserting party has a good faith belief are 27 within the definition set forth in subparagraph 2.1 of this Protective Order. Objections to such claims 28 made pursuant to paragraph 5, below, shall also be made only in good faith. 2 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 3 of 12 1 3.2 2 or contain Confidential Information shall state that the material is being produced under this 3 Protective Order by describing the documents or materials to be treated as confidential in writing, by 4 page or bates number wherever possible and/or shall produce copies bearing a label that contains or 5 includes language substantially identical to the following: CONFIDENTIAL 6 7 This label shall be affixed in a manner that does not obliterate or obscure the contents of the 8 copies. If any person or party makes copies of documents designated as containing Confidential 9 Information, the copying person or party shall mark each such copy as containing Confidential AKERMAN LLP 10 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Produced Documents. A party producing documents that it believes constitute Information in the same form as the Confidentiality notice on the original document. 11 A party producing documents that are stored on electronic, magnetic, optical or other non-paper 12 media, such as compact discs, DVD's, video tapes and audio tapes (collectively, "data storage 13 devices") shall designate the data storage device as containing Confidential Information, by affixing a 14 label or stamp to the data storage device in the manner described above at the time copies of such data 15 storage devices are produced. If the receiving party or other persons or entities to whom disclosure is 16 authorized pursuant to subparagraph 7.1 make a copy of any data storage device designated by the 17 producing party as containing Confidential Information, the receiving party or other authorized person 18 shall mark each such copy as containing Confidential Information in the same form as the 19 confidentiality notice on the original data storage device produced. If the receiving party or other 20 authorized person prints out or otherwise makes copies of the documents or information stored on 21 such data storage device, the receiving party or other authorized person shall mark each page so 22 copied with the label or stamp specified in subparagraph 3.2. 23 3.3 Interrogatory Answers. If a party answering an interrogatory or other discovery 24 demand believes that its answer contains Confidential Information, it shall state so in the interrogatory 25 response, and that portion of the response will be entitled to the protections of this order. 26 3.4 Inspection of Documents. In the event a party elects to produce files and 27 records for inspection and the requesting party elects to inspect them, no designation of Confidential 28 Information needs to be made in advance of the inspection. For purposes of such inspection, all 3 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 4 of 12 1 material produced shall be considered as Confidential Information. If the inspecting party selects 2 specified documents to be copied, the producing party shall designate Confidential Information in 3 accordance with subparagraph 3.2 at the time the copies are produced. 4 3.5 5 record the portions it deems confidential. 6 confidential shall be a waiver unless the designating party notifies all other parties and files a motion 7 to designate the testimony as confidential within 5 days of the notification. AKERMAN LLP 8 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Deposition Transcripts. The party asserting confidentiality shall state on the 3.6 The failure to designate testimony on the record as Inadvertent Failure to Designate. Inadvertent failure to identify documents or 9 things as "Confidential" pursuant to this Protective Order shall not constitute a waiver of any 10 otherwise valid claim for protection, provided that the provisions of this paragraph are satisfied. If the 11 designating party discovers that information should have but was not designated "Confidential" or of 12 the designating party receives notice that would enable the designated party to learn that it has 13 disclosed such information, the designating party must immediately notify all other parties. In such 14 event, within thirty (30) days of notifying all other parties, the designating parties must also provide 15 copies of the "Confidential" information designated in accordance with this Protective Order. After 16 receipt of such re-designated information, the "Confidential" information shall be treated as required 17 by this Protective Order, and the receiving party(ies) shall promptly, and in no event more than 18 fourteen (14) calendar days from the receipt of the re-designated information, return to the designated 19 party all previously produced copies of the same unlegended documents or things. The designating 20 party and the parties may agree to alternative means. The receiving party(ies) shall receive no 21 liability, under this Protective Order or otherwise, for any disclosure of information contained in 22 unlegended documents or things occurring before the receiving party was placed on notice of the 23 designating party's claims of confidentiality. 24 4. 25 Designations by Another Party. 4.1 Notification of Designation. If a party other than the producing party believes 26 that a producing party has produced a document that contains or constitutes Confidential Information 27 of the non-producing party, the non-producing party may designate the document as Confidential 28 Information by so notifying all parties in writing within fourteen (14) days of service of the document. 4 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 5 of 12 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 1 4.2 Return of Documents; Non-disclosure. Whenever a party other than the 2 producing party designates a document produced by a producing party as Confidential Information in 3 accordance with subparagraph 4.1, each party receiving the document shall either add the Confidential 4 Information designation in accordance with subparagraph 3.2 or substitute a copy of the document 5 bearing such designation for each copy of the document produced by the producing party. Each party 6 shall destroy all undesignated copies of the document or return those copies to the producing party, at 7 the direction of the producing party. No party shall disclose a produced document to any person, other 8 than the persons authorized to receive Confidential Information under subparagraph 7.1, until after the 9 expiration of the fourteen (14) day designation period specified in subparagraph 4.1. If during the 10 fourteen (14) day designation period a party discloses a produced document to a person authorized to 11 receive Confidential Information under subparagraph 7.1, and that document is subsequently 12 designated as Confidential Information in accordance with subparagraph 4.1, the disclosing party shall 13 cause all copies of the document to be destroyed or returned to the producing party, at the direction of 14 the producing party. The party may thereafter disclose a copy of the document that has been marked 15 as Confidential Information by the designating party, in accordance with subparagraphs 3.2 and 7.1. 16 5. Objections to Designations. Any party objecting to a designation of Confidential 17 Information, including objections to portions of designations of multi-page documents, shall notify the 18 designating party and all other parties of the objection in writing up to and through trial of the matter. 19 This notice must specifically identify each document that the objecting party in good faith believes 20 should not be designated as Confidential Information and provide a brief statement of the grounds for 21 such belief. In accordance with the Federal Rules of Civil Procedure governing discovery disputes, 22 the objecting and the designating parties thereafter shall confer within ten (10) days after the date of 23 such objection in an attempt to resolve their differences. If the parties are unable to resolve their 24 differences, the objecting party shall have twenty one (21) days after the conference concludes to file 25 with the Court a motion to remove the Confidential Information. If an objection is served within 26 forty-two (42) days of trial, the objecting party must file its motion to remove the Confidential 27 Information designation within half of the remaining time before trial, and the meet-and-confer period 28 shall be shortened accordingly. Where a party authored, created, owns, or controls a document, 5 55014460;1 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 6 of 12 1 information or other material that another party designates as Confidential Information, the party that 2 authored, created, owns, or controls the Confidential Information may so inform the objecting party 3 and thereafter shall also be considered a designating party for purposes of this paragraph. 4 All documents, information and other materials initially designated as Confidential Information 5 shall be treated as such in accordance with this Protective Order unless and until the Court rules 6 otherwise, except for deposition transcripts and exhibits initially considered as containing 7 Confidential Information under subparagraph 3.5, which will lose their confidential status after 8 twenty-one (21) days unless so designated as Confidential Information. If the Court rules that a 9 designation should not be maintained as to a particular document, the producing party shall, upon 10 written request by a party, provide that party a copy of that document without the designation 11 described in subparagraph 3.2. 12 If an objecting party elects not to make such a motion with respect to documents within twenty 13 one (21) days after the conference, information or other materials to which an objection has been 14 made, the objection shall be deemed withdrawn. The designating party shall have twenty one (21) 15 days to respond to the objecting party's motion. If no response is filed by the designating party within 16 twenty one (21) days, the designating party shall be deemed to have consented to the objecting party's 17 motion pursuant to LR 7-2(d). 18 6. Custody. All Confidential Information and any and all copies, extracts and summaries 19 thereof, including memoranda relating thereto, shall be retained by the receiving party in the custody 20 of counsel of record, or by persons to whom disclosure is authorized under subparagraph 7.1. 21 7. 22 23 Handling Prior to Trial. 7.1 Authorized Disclosures. Confidential Information shall be disclosed by the receiving party only to the following persons: 24 a. 25 Counsel for the parties in this litigation, including their associates, clerks, paralegals, and secretarial personnel; 26 b. Qualified persons taking testimony in this litigation involving such 27 Confidential Information, and necessary stenographic, videotape and 28 clerical personnel; 6 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 7 of 12 1 c. 2 a party in this litigation; 3 d. 4 e. Parties to this litigation, limited to the named party and, if that party is a 6 corporate entity, a limited number of employees of the corporate entity 7 and its insurers; 8 f. 9 Designated in-house counsel and a limited number of assistants, administrative or otherwise; 10 AKERMAN LLP Experts and their staff who are consulted by counsel for a party in this litigation; 5 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Experts and their staff who are retained by counsel as expert witnesses for g. 11 Outside vendors employed by counsel for copying, scanning and general handling of documents; 12 h. Any person of whom testimony is taken regarding the Confidential 13 Information, except that such person may only be shown Confidential 14 Information during his/her testimony, and may not retain a copy of such 15 Confidential Information; and 16 i. 17 materials under seal. 18 19 This Court and this Court's staff, subject to the Court's processes for filing Such disclosures are authorized only to the extent necessary to investigate, prosecute, or defend the litigation. 20 Confidential Information may not be disclosed to persons under subparagraphs (c) or (d) until 21 the receiving party has obtained a written acknowledgment from the person receiving Confidential 22 Information, in the form of the Declaration attached hereto as Exhibit A, that he or she has received a 23 copy of this Protective Order and has agreed to be bound by it. A party who discloses Confidential 24 Information in accordance with subparagraph 7.1 shall retain the written acknowledgment from each 25 person receiving Confidential Information, shall maintain a list of all persons to whom a receiving 26 party has disclosed Confidential Information and identify what documents have been disclosed, and 27 shall furnish the written acknowledgments and disclosure list to opposing counsel as follows: (i) for a 28 person under subparagraph (c), within thirty (30) days after the person signs the Declaration; and (ii) 7 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 8 of 12 1 for a person under subparagraph (d), within thirty (30) days after the matter is finally concluded. 2 Disclosure of Confidential Information to this Court, including judicial staff, shall be made in 3 accordance with subparagraph 7.4 of this Protective Order. AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 4 7.2 Unauthorized Disclosures. All persons receiving Confidential Information 5 under the terms of this Protective Order are under the jurisdiction of the state courts and U.S. federal 6 courts located in Nevada for all matters arising from the improper disclosure or use of such 7 information. If Confidential Information is disclosed to any person other than in the manner 8 authorized by this Protective Order, the party or person responsible for the disclosure, and any other 9 party or person who is subject to this Protective Order and learns of such disclosure, shall immediately 10 bring such disclosure to the attention of the designating party. Without prejudice to other rights and 11 remedies of the designating party, the responsible party or person shall make every effort to obtain 12 and return the Confidential Information and to prevent further disclosure on its own part or on the part 13 of the person who was the unauthorized recipient of such information. 14 7.3 Court Filings. In the event any Confidential Information must be filed with the 15 Court prior to trial, the proposed filing shall be accompanied by a motion to file the Confidential 16 Information under seal that complies with Local Rule 10-5(b) and a proposed order, and the 17 application and proposed order shall be directed to the judge to whom the Confidential Information is 18 directed. This provision is applicable to briefs, memoranda, and other filings which quote, summarize, 19 or describe Confidential Information. 20 8. Care in Storage. Any person in possession of Confidential Information produced by 21 another party shall exercise reasonable and appropriate care with regard to the storage, custody, 22 copying, and use of such information to ensure that the confidential and sensitive nature of same is 23 maintained. 24 9. Handling During Trial. Confidential Information that is subject to this Order may be 25 marked and used as trial exhibits by either party, subject to terms and conditions as imposed by the 26 Court upon application by any party. 27 28 10. No Implied Waivers. This Protective Order shall not be interpreted as a waiver of the right to object, under applicable law, to the furnishing of information in response to discovery requests 8 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 9 of 12 1 or to object to a requested inspection of documents or facilities. Parties producing Confidential 2 Information in this litigation are doing so only pursuant to the terms of this Protective Order. The 3 taking of any action in accordance with the provisions of this Protective Order shall not be interpreted 4 as a waiver of any claim or position or defense in this action, or any other actions. 5 AKERMAN LLP No Admission. The designation of any item as Confidential Information shall not be 6 construed as an admission that such material, or any testimony concerning such material, would be 7 admissible in evidence in this litigation or in any other proceeding. 8 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 11. 12. Inadvertent Disclosure. Nothing in this Protective Order abridges applicable law 9 concerning inadvertent disclosure of a document that the Disclosing Party believes contains attorney- 10 client communications, attorney work product, or otherwise privileged information. If a party 11 inadvertently discloses documents or information subject to a claim of privilege or work product 12 protection, such disclosure will not waive otherwise applicable claims of privilege or work product 13 protection under applicable law. Upon discovery by the Receiving Party, or receipt of written notice 14 from the Disclosing Party identifying privileged or protected Documents that were inadvertently 15 produced, the receiving party shall within seven (7) business days either: (a) return or certify the 16 destruction of all such documents, all copies, and any work product or portions of any work product 17 containing or reflecting the contents of the subject materials; or (b) after attempting to resolve any 18 dispute with opposing counsel informally, file a motion to challenge the assertion of privilege and 19 tender the subject documents for in camera review with the motion. The moving party shall do 20 nothing to compromise the privilege claim until the Court rules on said motion and the opportunity for 21 appellate review is exhausted or the issue is otherwise resolved. 22 13. Parties' Own Documents. This Protective Order shall in no way restrict the parties in 23 their use of their own documents and information, and nothing in this Protective Order shall preclude 24 any party from voluntarily disclosing its own documents or information to any party or nonparty. 25 14. Motion by Third Party to Compel Production of Confidential Information. If any 26 third party subpoenas Confidential Information from a party to this action or moves to compel a party 27 to this action to produce any such information, such party shall immediately notify the parties who 28 originally produced and/or designated such information that a subpoena has been served or a motion 9 55014460;1 AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 10 of 12 1 has been made in order to allow the parties who originally produced and/or designated such 2 information the opportunity to seek a protective order or oppose the motion or application. If, within 3 thirty (30) days after receiving notice of a subpoena seeking Confidential Information from a 4 receiving party, the party who originally produced and/or designated such information fails to move 5 for a protective order, the party subject to the subpoena may produce said information. In addition, if a 6 party is ordered to produce Confidential Information covered by this Protective Order, then notice 7 and, if available, a copy of the order compelling disclosure shall immediately be given the parties who 8 originally produced and/or designated such information. Nothing in this Protective Order shall be 9 construed as requiring the party who is ordered to produce such Confidential Information to challenge 10 or appeal any order requiring the production of such information or to subject himself/herself to any 11 penalty for non-compliance with any legal process or seek any relief from the Court. 12 15. No Effect on Other Rights. This Protective Order shall in no way abrogate or 13 diminish any pre-existing contractual, statutory, or other legal obligations or rights of any party with 14 respect to Confidential Information. 15 16. Modification. In the event any party hereto seeks a Court order to modify the terms of 16 this Protective Order, or seeks a protective order which incorporates the terms and conditions of this 17 Protective Order said party shall make such request by written stipulation or noticed motion to all 18 parties that must be served and filed in accordance with local court rules. 19 17. Handling Upon Conclusion of Litigation. All parties, counsel, and persons to whom 20 disclosure was made agree to return all Confidential Information to the designating party within thirty 21 (30) days of the conclusion of litigation between the parties, including final appellate action or the 22 expiration of time to appeal or seek further review. In addition, counsel shall certify in writing that all 23 such Confidential Information have been returned. Counsel for each party also shall contact each 24 person to whom that party has provided a copy of any Confidential Information and request the 25 documents be returned. In lieu of returning Confidential Information, the person or party in possession 26 of such information may elect to destroy it. If the person or party in possession of Confidential 27 Information elects to destroy it rather than return it, that person or party must notify the designating 28 party in writing of the destruction of the information within ninety (90) days of the conclusion of 10 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 11 of 12 1 litigation between the parties, including final appellate action or the expiration of time to appeal or 2 seek further review. 3 18. Survival of the Terms of this Protective Order. Even after the termination of this 4 litigation, the confidentiality obligations imposed by this Protective Order shall remain in effect until 5 a Designating Party otherwise in writing or a court order otherwise directs. 6 DATED this 8th day of January, 2021. 7 8 AKERMAN LLP HONG & HONG LAW OFFICE 9 /s/ Natalie L. Winslow ARIEL E. STERN, ESQ. Nevada Bar No. 8276 NATALIE L. WINSLOW, ESQ. Nevada Bar No. 12125 NICHOLAS E. BELAY, ESQ. Nevada Bar No. 15175 1635 Village Center Circle, Suite 200 Las Vegas, NV 89134 /s/ Joseph Y. Hong JOSEPH Y. HONG, ESQ. Nevada Bar No. 5995 1980 Festival Plaza Drive, Suite 650 Las Vegas, NV 89135 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 Attorneys for Joel A. Stokes and Sandra F. Stokes, as Trustees of the Jimijack Irrevocable Trust Attorneys for NewRez LLC dba Shellpoint Mortgage Servicing 15 16 IT IS SO ORDERED. ORDER 17 IT IS SO ORDERED 18 _____________________________________ 11, 2021 DATED: 4:06 pm, January UNITED STATES MAGISTRATE JUDGE 19 20 DATED: __________________________ BRENDA WEKSLER UNITED STATES MAGISTRATE JUDGE 21 22 23 24 25 26 27 28 11 55014460;1 Case 2:20-cv-00946-JCM-BNW Document 14 Filed 01/08/21 Page 12 of 12 EXHIBIT A ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND AKERMAN LLP 1635 VILLAGE CENTER CIRCLE, SUITE 200 LAS VEGAS, NEVADA 89134 TEL.: (702) 634-5000 – FAX: (702) 380-8572 1 2 I, ______________________, and read in its entirety and understand the Protective Order 3 that was issued by the United States District Court, for the District of Nevada, on 4 ________________, 2020, in the case of NewRez LLC dba Shellpoint Mortgage Servicing v. Joel A. 5 Stokes, et al., Case No.: 2:20-cv-00946-JCM-BNW. I agree to comply with and be bound by all 6 terms of this Protective Order and I understand and acknowledge that failure to so comply could 7 expose me to sanctions and punishment in the nature of contempt. I solemnly promise that I will not 8 disclose in any manner any information or item that is subject to this Protective Order to any person 9 or entity except in strict compliance with this Protective Order. Further, I solemnly promise that I 10 will not offer to sell, advertise or publicize that I have obtained any protected material subject to this 11 Protective Order. 12 At the conclusion of this matter, I will return all protected materials which came into my 13 possession or control to counsel for the party from whom I received the protected material, or I will 14 destroy those materials. 15 summaries of protected material shall remain protected pursuant to the terms of this Order. I understand that any confidential information contained within any 16 I further agree to submit to the jurisdiction of the United States District Court, for the District 17 of Nevada for the purpose of enforcing the terms of this Protective Order, even if such enforcement 18 proceedings occur after termination of this action. 19 I certify under penalty of perjury that the foregoing is true and correct. 20 Date: ____________________________ 21 City and State where signed: ________________________________ 22 Printed Name: ___________________________________________ 23 Address: ________________________________________________ 24 Signature: _______________________________________________ 25 26 27 28 12 55014460;1
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