United States District Court, D. Nevada
IN RE OCWEN LOAN SERVICING, LLC This Document Relates To: ALL ACTIONS
Christopher P. Burke (Nevada Bar No. 4093) CHRISTOPHER P.
BURKE, ESQ. AND ASSOCIATES Scott C. Borison (Pro hac vice)
LEGG LAW FIRM LLP Attorneys for Plaintiffs Christopher
Marino, Henry L, Farrin, Joshua E. Hardin, and Kristen J.
A. Holland (Pro hac vice) HOLLAND LAW FIRM Attorneys for
Plaintiffs Henry L. Farrin, Joshua E. Hardin, and Kristen J.
Mitchell D. Gliner (Nevada Bar No. 3419) THE LAW OFFICE OF
MITCHELL D. GLINER Sylvia Antalis Goldsmith (Pro hac vice)
GOLDSMITH & ASSOCIATES Attorneys for Plaintiffs Dionne
Horton, Deaonca S. Bouguere, Pernelt D, Hobley and Michael D.
E. Schnitzer Gary E. Schnitzer (Nevada Bar No. 395) Jordan P.
Schnitzer (Nevada Bar No. 10744) KRAVITZ, SCHNITZER &
JOHNSON, CHTD. John C. Lynch (Admitted pro hac vice) Ethan G.
Ostroff (Admitted pro hac vice) TROUTMAN SANDERS LLP Michael
E. Lacy, (Admitted pro hac vice) H. Scott Kelly, (Admitted
pro hac vice) TROUTMAN SANDERS LLP Attorneys for Defendant
Ocwen Loan Servicing, LLC
parties have agreed to the terms of this Protective Order;
accordingly, it is ORDERED:
documents produced in the course of discovery, including
initial disclosures, all responses to discovery requests, all
responses to third-party subpoenas, all deposition testimony
and exhibits, other materials which may be subject to
restrictions on disclosure for good cause and information
derived directly therefrom (hereinafter collectively
"document(s)"), shall be subject to this Order
concerning confidential information as set forth below. This
Order is subject to the Local Rules of this District and of
the Federal Rules of Civil Procedure on matters of procedure
and calculation of time periods.
Form and Timing of Designation.
may designate documents as confidential and restricted in
disclosure under this Order by placing or affixing the words
"CONFIDENTIAL" on the document in a manner that
will not interfere with the legibility of the document and
that will permit complete removal of the CONFIDENTIAL
designation. Documents shall be designated CONFIDENTIAL prior
to or at the time of the production or disclosure of the
documents. The designation "CONFIDENTIAL" does not
mean that the document has any status or protection by
statute or otherwise except to the extent and for the
purposes of this Order.
Documents Which May be Designated
party may designate documents as CONFIDENTIAL but only after
review of the documents by an attorney or a party appearing
pro se who has in good faith determined that the documents
contain information protected from disclosure by statute or
that should be protected from disclosure as confidential
personal information, trade secrets, personnel records, or
commercial information. The designation shall be made subject
to the standards of Rule 11 and the sanctions of Rule 37 of
the Federal Rules of Civil Procedure. Information or
documents that are available in the public sector may not be
designated as CONFIDENTIAL.
testimony shall be deemed CONFIDENTIAL only if designated as
such. Such designation shall be specific as to the portions
to be designated CONFIDENTIAL. Depositions, in whole or in
part, shall be designated on the record as CONFIDENTIAL at
the time of the deposition. Deposition testimony so
designated shall remain CONFIDENTIAL until fifteen (15) days
after delivery of the transcript by the court reporter.
Within fifteen (15) days after delivery of the transcript, a
designating party may serve a Notice of Designation to all
parties of record as to specific portions of the transcript
to be designated CONFIDENTIAL. Thereafter, those portions so
designated shall be protected as CONFIDENTIAL pending
objection under the terms of this Order. The failure to serve
a Notice of Designation shall waive the CONFIDENTIAL
designation made on the record of the deposition.
Protection of Confidential Material.
General Protections. Documents designated
CONFIDENTIAL under this Order shall not be used or disclosed
by the parties, counsel for the parties or any other persons
identified in ¶ 5.b. for any purpose whatsoever other
than to prepare for and to conduct discovery, hearings and
trial in this action, including any appeal thereof.
Limited Third-Party Disclosures. The parties and
counsel for the parties shall not disclose or permit the
disclosure of any CONFIDENTIAL documents to any third person
or entity except as set forth in subparagraphs 1-6. Subject
to these requirements, the following categories of ...