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Morgan v. Ocwen Loan Servicing

United States District Court, D. Nevada

August 22, 2017

CAROL MORGAN, an individual, Plaintiff,
v.
OCWEN LOAN SERVICING, a corporation; and DOES I through X, inclusive, Defendant.

          GREENBERG TRAURIG, LLP JACOB D. BUNDICK, ESQ. Nevada Bar No. 9772 LISA J. ZASTROW, ESQ. Nevada Bar No. 9727 Counsel for Defendant Ocwen Loan Servicing

          LAW OFFICE OF MICHAEL J. HARKER MICHAEL J. HARKER, ESQ., Nevada Bar No. 5353 Counsel for Plaintiff Carol Morgan

          JACOB D. BUNDICK, ESQ. Nevada Bar No. 9772 LISAJ.ZASTROW, ESQ. Nevada Bar No. 9727 GREENBERG TRAURIG, LLP Counsel for Defendant Ocwen Loan Servicing

          STIPULATED CONFIDENTIALITY AGREEMENT AND PROTECTIVE ORDER

         Plaintiff, Carol Morgan ("Plaintiff), and Defendant, Ocwen Loan Servicing ("Ocwen") (collectively, the "Parties"), hereby enter into the following Stipulated Confidentiality Agreement and Protective Order ("Protective Order").

         Based upon the mutual order reflected in this stipulation, the Parties agree as follows: 1. This Protective Order shall govern all documents, materials, depositions, testimony, transcripts, responses to requests for admissions, interrogatory responses, items, and/or other information obtained or provided through discovery in this action (collectively "Information") that a Party designates as "Confidential" or "Confidential - Attorney's Eyes Only" pursuant to the terms hereof (collectively "Confidential Information").

         2. Any Party that produces Information in this action and has a good faith and reasonable basis for claiming that such Information constitutes confidential and/or proprietary information may designate such Information as Confidential Information. Any Party that produces Information, and has a reasonable basis for claiming that such Information would not be sufficiently protected through designation under this Protective Order as Confidential Information (for example, because of a significant competitive advantage that is likely to be gained from it), may designate such Information as "Confidential - Attorney's Eyes Only."

         a. For documents, materials, or other written Information, a Party shall designate such Information as Confidential Information by stamping or otherwise labeling each page or item containing Confidential Information as "Confidential" or "Confidential - Attorney's Eyes Only."

         b. For interrogatories and written discovery, designation shall be made by placing the legend "Confidential" on any page(s) of any answer deemed to contain such confidential information, indicating any portion of such page which does not contain such confidential information. Alternatively, answers deemed to contain confidential information may be bound separately and marked with the appropriate legend.

         c. For testimony, a Party shall designate such Information as Confidential Information on the record or within 30 days after receipt of the official transcript. Until the 30 day period has expired, the entire transcript shall be considered "Confidential - Attorney's Eyes Only, " Such Party shall also require the court reporter to label the portion of the transcript containing the information as "Confidential" or "Confidential - Attorney's Eyes Only."

         d. A Party's inadvertent or unintentional failure to designate Information as Confidential Information or "Confidential - Attorney's Eyes Only" shall not be deemed a waiver in whole or in part of that Party's claim of confidentiality, if the disclosing Party takes prompt action after discovering such omission to notify all Parties in writing that such Information constitutes Confidential Information or "Confidential - Attorney's Eyes Only." However, the Party who received that Information without knowledge of its confidential nature may not be held in violation of this Order for using or disclosing that Information before notification of the inadvertent or unintentional failure to designate that Information as Confidential Information or "Confidential - Attorney's Eyes Only."

         3. The designation of information as Confidential Information pursuant to this Protective Order shall not preclude any Party from disclosing that information to any person who, in the case of a document, appears as the author or as a recipient thereof on the face of the document, or from disclosing that information to any person who has been identified by the designating party ("Designating Party") as having previously been provided with, or having had access to, the document or the information therein.

         4. In the event a Designating Party elects to produce documents for inspection and the receiving Party desires to inspect them before designating them for copying, the Designating Party need not mark the documents in advance of any such inspection. For purposes of the inspection, and any subsequent inspection of the original documents, all documents produced for inspection shall be deemed to be designated as Confidential Information. Thereafter, upon selection of specified documents for copying by the receiving Party, the Designating Party may make the appropriate confidentiality designation at the time the copies are produced to the receiving party.

         5. The Parties shall use information designated as Confidential or "Confidential -Attorney's Eyes Only" solely for purposes of these proceedings and not for any other purpose whatsoever, unless the Court permits such additional use or disclosure upon noticed motion served on all parties, including the Party that produced the Confidential Information.

         6. The Parties may use Confidential Information in discovery responses, motions, briefs, and other pleadings, may mark Confidential Information as exhibits, and may use Confidential Information ...


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