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In re Ocwen Loan Servicing, LLC

United States District Court, D. Nevada

January 17, 2017

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. Hardin

          Peter A. Holland (Pro hac vice) HOLLAND LAW FIRM Attorneys for Plaintiffs Henry L. Farrin, Joshua E. Hardin, and Kristen J. Hardin

          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. Wittreich

          Gary 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

          PROTECTIVE ORDER

         The parties have agreed to the terms of this Protective Order; accordingly, it is ORDERED:

         1. Scope.

         All 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.

         2. Form and Timing of Designation.

         A party 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.

         3. Documents Which May be Designated CONFIDENTIAL.

         Any 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.

         4. Depositions.

         Deposition 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.

         5. Protection of Confidential Material.

         a. 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.

         b. 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 ...


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