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HSBC Bank USA, N.A. v. Maccord

United States District Court, W.D. Washington, Seattle

November 1, 2017

HSBC BANK USA, NATIONAL ASSOCIATION AS TRUSTEE FOR THE J.P. MORGAN ALTERNATIVE LOAN TRUST 2006-A7, Plaintiff,
v.
DONALD E. MACCORD et al., Defendants. DONALD E. MACCORD, Counterclaim Plaintiff,
v.
NATIONSTAR MORTGAGE LLC, HSBC BANK USA, NATIONAL ASSOCIATION AS TRUSTEE FOR THE J.P. MORGAN ALTERNATIVE LOAN TRUST 2006-A7, Counterclaim Defendants.

          Daniel J. Gibbons, WSBA# 33036 WITHERSPOON ∙ KELLEY Attorneys for Plaintiff/Counterclaim Defendants HSBC Bank USA, National Association as Trustee for the J.P. Morgan Alternative Loan Trust 2006-A7 and Counterclaim Defendant Nationstar Mortgage LLC.

          CORR CRONIN MICHELSON BAUMGARDNER FOGG & MOORE LLP Todd T. Williams, Steven W. Fogg, Mallory L. B. Satre, Corr Cronin Michelson Baumgardner Fogg & Moore LLP Of Attorneys for Defendant/Counter Claimant Donald E. MacCord.

          STIPULATED PROTECTIVE ORDER

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE.

         1. PURPOSES AND LIMITATIONS

         Discovery in this action is likely to involve production of confidential, proprietary, or private information for which special protection may be warranted. Accordingly, Plaintiff/Counterclaim Defendant HSBC Bank USA, National Association As Trustee For The J.P. Morgan Alternative Loan Trust 2006-A7 (“HSBC”), Counterclaim Defendant Nationstar Mortgage LLC (“Nationstar”) (hereinafter, collectively referred to as “Plaintiffs”), and Defendant/Counterclaim Plaintiff Donald E. MacCord (“Defendant”) hereby stipulate to and petition the court to enter the following Stipulated Protective Order. The stipulating parties acknowledge that this agreement is consistent with LCR 26(c). It does not confer blanket protection on all disclosures or responses to discovery, the protection it affords from public disclosure and use extends only to the limited information or items that are entitled to confidential treatment under the applicable legal principles, and it does not presumptively entitle parties to file confidential information under seal.

         2. “CONFIDENTIAL” MATERIAL

         “Confidential” material shall include the following documents and tangible things produced or otherwise exchanged:

a. Confidential personal financial information of the Defendant-including bank account numbers, former or current loan numbers, social security numbers, etc. (not otherwise already in the possession of the parties to this agreement) - included on loan applications, bank statements, mortgage statements, tax returns, etc.
b. Plaintiffs' proprietary systems for servicing loans, including its loan servicing notes created to record pertinent information relating to loans, including contacts with Plaintiffs, and codes created by BANA to reflect the status of the loan, including but not limited to any codes concerning any cost, fee, or advance, including any property inspection fee, late fee, attorney fee, or other default-related fee, cost, or advance assessed, charged or added to the Loan.
c. Information that is proprietary in nature; which contain trade secret; agent or subcontractor or subcontractor information; or contain party or non-party consumer specific information and documents, including private consumer information that contains identifying, contact or private financial information concerning a consumer.

         3. SCOPE

         The protections conferred by this agreement cover not only confidential material (as defined above), but also (1) any information copied or extracted from confidential material; (2) all copies, excerpts, summaries, or compilations of confidential material; and (3) any testimony, conversations, or presentations by parties or their counsel that might reveal confidential material. However, the protections conferred by this agreement do not cover information that is in the public domain or becomes part of the public domain through trial or otherwise.

         4. ACCESS TO AND USE OF CONFIDENTIAL MATERIAL

         4.1 Basic Principles. A receiving party may use confidential material that is disclosed or produced by another party or by a non-party in connection with this case only for prosecuting, defending, or attempting to settle this litigation. Confidential material may be disclosed only to the categories of persons and under the conditions described in this agreement. Confidential material must be stored and maintained by a receiving party at a location and in a secure manner that ensures that access is limited to the persons authorized under this agreement.

         4.2 Disclosure of “CONFIDENTIAL” Information or Items. Unless otherwise ordered by the court or permitted in writing by the designating party, a receiving party may disclose any confidential material only to:

(a) the receiving party's counsel of record in this action, as well as employees of counsel to whom it is reasonably necessary to disclose the information for this litigation;
(b) the officers, directors, and employees (including in house counsel) of the receiving party to whom disclosure is reasonably necessary for this litigation, unless the parties agree that a particular document or material produced ...

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