Court filing
Exhibit — Exhibit (Dkt. 19.2) (Dkt. 19.2)
No. 5:21-cv-04337-JMG · Doc. 19-2 · Docket on CourtListener
Summary
A [Proposed] Stipulated Protective Order, marked Exhibit A and filed January 14, 2022 as Doc. 19-2 in Alicia Marshall, Daniel Pronsky and Paris Townsend v. Prestamos CDFI, LLC, Case No. 5:21-cv-04337-JMG, in the U.S. District Court for the Eastern District of Pennsylvania. Under Federal Rule of Civil Procedure 26(c), the order would let parties designate discovery material Confidential or Highly Confidential and lists who may receive each tier. Parties and deponents could designate deposition transcripts within thirty (30) calendar days of receiving the final transcript. Its terms would not extend beyond the start of trial except for material not used at trial, and a party filing designated material would file a redacted copy. It closes with an unsigned signature line for Judge John M. Gallagher and a form Acknowledgment and Consent to Be Bound.
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Case 5:21-cv-04337-JMG Document 19-2 Filed 01/14/22 Page 1 of 20
EXHIBIT A
Case 5:21-cv-04337-JMG Document 19-2 Filed 01/14/22 Page 2 of 20
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ALICIA MARSHALL, DANIEL
PRONSKY, and PARIS TOWNSEND,
individually, and on behalf of all others
Case No. 5:21-cv-04337-JMG
similarly situated,
Plaintiffs,
v.
PRESTAMOS CDFI, LLC,
Defendant.
[PROPOSED] STIPULATED PROTECTIVE ORDER
To facilitate the exchange of discovery material, assist with the resolution of potential
disputes over confidentiality, and protect against improper disclosure of Discovery Material
entitled to protection under Federal Rule of Civil Procedure 26(c), the Parties agree that this
Stipulated Protective Order (“Protective Order”) shall govern the above-captioned action (the
“Action”).
This Action is likely to involve the production of confidential business or financial
information, including personal financial information regarding individuals’ financial
transactions or financial accounts, sensitive trade secrets and intellectual property, and other
information which is otherwise not available to the public, for which special protection from
public disclosure and from use for any purpose other than prosecution of this Action is
warranted. Such confidential and proprietary materials and information consist of, among other
things, confidential business or financial information, sensitive trade secrets and intellectual
property, information regarding confidential business practices, including information
implicating the privacy rights of individuals, information otherwise generally unavailable to the
Case 5:21-cv-04337-JMG Document 19-2 Filed 01/14/22 Page 3 of 20
public, or which may be privileged or otherwise protected from disclosure under state or federal
statutes, court rules, case decisions, or common law.
Accordingly, to expedite the flow of information, to facilitate the prompt resolution of
disputes over confidentiality of discovery materials, to adequately protect information the parties
are entitled to keep confidential, to ensure that the parties are permitted reasonable necessary
uses of such material in preparation for and in the conduct of trial, to address their handling at
the end of the litigation, and serve the ends of justice, a protective order for such information is
justified in this matter. It is the intent of the parties that information will not be designated as
confidential for tactical reasons and that nothing be so designated without a good faith belief that
it has been maintained in a confidential, non-public manner, and there is good cause why it
should not be part of the public record of this case.
Based upon this stipulation, it is hereby ORDERED as follows:
1. Definitions
a. “Confidential” Discovery Material shall mean Discovery Material (regardless of
how it is generated, stored or maintained) that qualifies for protection under Federal Rule of
Civil Procedure 26(c), and as specified above in the Good Cause Statement.
b. “Counsel” shall mean Outside Counsel of Record and House Counsel (as well as
their support staff).
c. “Designated Material” shall mean any Discovery Material designated as
Confidential or Highly Confidential by a Designating Party.
d. “Designating Party” shall mean a Party or non-party that designates Discovery
Material as Confidential or Highly Confidential.
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e. “Discovery Material” shall mean all items or information, regardless of the
medium or manner in which it is generated, stored, or maintained (including, among other things,
testimony, transcripts, and tangible things), that are produced or generated in disclosures or
responses to discovery in this matter.
f. “Highly Confidential” Discovery Material shall mean extremely sensitive
Confidential Discovery Material that the Designating Party believes in good faith would not
otherwise be adequately protected under the procedures set forth herein if designated
Confidential, including but not limited to trade secrets or other information that the Designating
Party reasonably believes the unauthorized disclosure of which would result in competitive,
commercial, or financial harm to the Designating Party or its personnel, clients, or customers.
g. “House Counsel” shall mean attorneys who are employees of a party to this
Action. House Counsel does not include Outside Counsel of Record or any other outside counsel.
h. “Outside Counsel of Record” shall mean attorneys who are not employees of a
party to this Action, but are retained to represent or advise a party to this Action and have
appeared in this Action on behalf of that party or are affiliated with a law firm that has appeared
on behalf of that party, and includes support staff.
i. “Party” shall mean any current or future Plaintiffs or Defendants in this Action,
including their employees, officers, directors, and principals acting or purporting to act on their
behalf.
j. “Producing Party” shall mean a Party or non-party that produces Discovery
Material in this Action.
k. “Protected Discovery Material” shall mean Confidential Discovery Material and
Highly Confidential Discovery Material.
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l. “Receiving Party” shall mean a Party that receives Discovery Material from a
Producing Party in this Action.
2. Scope
a. The protections conferred by this Stipulation and Order cover not only Protected
Discovery Material (as defined above), but also: (1) any information copied or extracted from
Protected Discovery Material; (2) all copies, excerpts, summaries, or compilations of Protected
Discovery Material; and (3) any testimony, conversations, or presentations by Parties or their
Counsel that might reveal Protected Discovery Material.
b. Any use of Protected Discovery Material at trial shall be governed by the orders
of the Court. This Protective Order does not govern the use of Protected Discovery Material at
trial.
3. Duration
Once a case proceeds to trial, Protected Discovery Material that is used or introduced as
an exhibit at trial becomes public and will be presumptively available to all members of the
public, including the press, unless compelling reasons to proceed otherwise are made to the
Court in advance of the trial. Accordingly, the terms of this Protective Order do not extend
beyond the commencement of the trial, with two exceptions:
a. Any Protected Discovery Material that is not used or introduced as an exhibit at
trial shall remain protected under this Protective Order and be subject to final disposition as set
forth in Section 15.
b. Should resolution be reached prior to a trial, the terms of this Protective Order
extend up to final disposition of the Action.
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4. Designating Confidential or Highly Confidential Discovery Material in Documents
a. Any Producing Party may designate Discovery Material as Confidential or Highly
Confidential, and such material shall be treated in accordance with the provisions of this
Protective Order, provided that the materials are stamped or marked in such a manner that they
are prominently designated Confidential or Highly Confidential. If Discovery Material entitled to
protection is included in written answers to discovery requests of any kind, the portions of such
answers or responses that contain Confidential or Highly Confidential Discovery Material shall
be marked Confidential or Highly Confidential. To the extent a Party wishes or is required to file
Confidential or Highly Confidential Discovery Material with the Court, the Party shall
electronically file a redacted copy, or a partially redacted copy masking only the portion of the
Discovery Material designated Confidential or Highly Confidential and simultaneously serve an
unredacted copy of the document on all Parties to this Action and on the Court.
b. If a Producing Party is asked to produce a non-party’s documents or tangible
things, the Producing Party will in good faith designate materials as Confidential or Highly
Confidential in conformance with any pre-existing confidentiality obligations to the non-party
and/or designations requested by the non-party, or otherwise in good faith to protect the non-
party’s sensitive information. Parties will confer with the non-party as practicable to ensure
appropriate confidentiality designations.
c. Each Party or non-party that designates Discovery Materials Confidential or
Highly Confidential under this Order must take care to limit any such designation to the specific
material that qualifies under the appropriate standard. To the extent it is practical to do so, the
Designating Party must designate only those parts of the Discovery Material that qualify as
Confidential or Highly Confidential, so that other portions of the Discovery Material for which
the protections of this Order are not warranted are not unjustifiability included.
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d. If it comes to the Designating Party’s attention that Discovery Material designated
Confidential or Highly Confidential does not quality for such protection, it must promptly notify
the Receiving Parties in writing that it is withdrawing the designation and, at its own expense,
produce new copies of the Discovery Materials with the appropriate designation within fourteen
(14) calendar days.
e. The protections of this Order do not apply to: (a) any Discovery Material that is
publicly available or in the public domain at the time of disclosure to a Receiving Party or
becomes part of the public domain after its disclosure to a Receiving Party as a result of
publication or other event not involving a violation of this Order, including becoming part of the
public record through trial or otherwise; and (b) any Discovery Material in the possession of
Receiving Party prior to disclosure or obtained by the Receiving Party after disclosure from a
source who obtained the information lawfully and is under no obligation of confidentiality to the
Designating Party.
f. If timely corrected, an inadvertent failure to designate qualified Discovery
Material does not, standing alone, waive the Designating Party’s right to secure protection under
this Order for such material. Upon timely correction of a designation, the Receiving Party must
make reasonable efforts to assure that the material is treated in accordance with the provisions of
this Protective Order.
5. Designating Confidential or Highly Confidential Discovery Material in Depositions
a. Discovery Material previously marked as Confidential or Highly Confidential
shall remain such even if used at deposition. In addition, Parties and deponents may, within thirty
(30) calendar days after receiving a final transcript of a deposition from the court reporter,
designate the transcript (and/or exhibits thereto) as Confidential or Highly Confidential by oral
or written notice to the Parties present and the stenographer and the videographer. During the 30-
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day designation period, all deposition transcripts shall be treated as Highly Confidential. To the
extent deposition material is designated as Confidential or Highly Confidential, the transcript of
the designated testimony shall be bound in a separate volume and marked “CONFIDENTIAL
INFORMATION GOVERNED BY PROTECTIVE ORDER” or “HIGHLY CONFIDENTIAL
INFORMATION GOVERNED BY PROTECTIVE ORDER” by the reporter.
b. Counsel for the witness or counsel for any Party, Producing Party, or Designating
Party shall have the right to exclude from attendance at portions of depositions related to
Confidential or Highly Confidential Discovery Material any person who is not authorized by this
Order to receive such Discovery Material.
6. Use of Designated Material is Limited to This Action Only
Unless otherwise ordered by this Court or any other court, administrative agency, or
similar governmental or regulatory body, Designated Material may be used only in connection
with the prosecution or defense of claims in, or the settlement of, this action.
7. Disclosure of Confidential and Highly Confidential Discovery Material
a. Confidential Discovery Material may only be disclosed to:
i. Parties in this Action;
ii. House Counsel for the Parties and their internal legal, investigative, technical,
administrative, and other support staff engaged in the conduct of this Action;
iii. Outside Counsel retained specifically for this Action, and their respective
legal, investigative, technical, administrative, and other support staff engaged
in the conduct of this Action;
iv. This Court, or any other court exercising jurisdiction with respect to this
Action, and any court personnel or other qualified persons involved in this
Action, including clerical personnel, jurors, court reporters, or those
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recording, taking, or transcribing testimony or argument at any deposition,
hearing, trial, or appeal in this Action;
v. Witnesses at depositions, hearings, or trial that are not Parties or employed by
Parties and who have executed the “Acknowledgment and Consent to Be
Bound by Protective Order” (“Acknowledgment”) attached as Exhibit A to
this Protective Order, provided that the examiner has a good faith belief that
the witness is likely to have prior knowledge of the subject matter of the
Discovery Material;
vi. Any person designated by the Court to have authority to view protected
material upon such terms as the Court may deem proper;
vii. Any special master, mediator, or arbitrator engaged by the Parties or
authorized by the Court for purposes of mediation, arbitration, or other dispute
resolution regarding issues arising in this Action, provided that they have
executed the Acknowledgment;
viii. Outside consultants, investigators, or experts retained for the purpose of
assisting counsel or testifying in this Action, provided that they have executed
the Acknowledgment;
ix. Third-party contractors engaged for litigation support, including those
involved in copying, organizing, filing, coding, converting, storing, or
retrieving Discovery Material or designing and maintaining computerized
programs for handling Discovery Material, provided that they have executed
the Acknowledgment;
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x. The person or entity that produced or originally created the designated
Discovery Material;
xi. Any author, addressee, or recipient of the designated Discovery Material as
indicated on its face;
xii. ;
xiii. Any other person agreed to in writing by the Designating Party, which
agreement shall not be unreasonably withheld.
b. Highly Confidential Discovery Material may only be disclosed to those persons or
entities identified in Section 7.a.ii-xiii, provided that such person or entity has executed the
Acknowledgment if such execution is required for disclosure to that person of Confidential
Discovery Material, as set forth above.
8. Signing a Consent to be Bound by the Protective Order
a. As described in Section 7, above, certain persons must execute the
Acknowledgment appended as Exhibit A and agree—before any Designated Material is
disclosed—that they: (a) read, understood, and will abide by the terms of this Order; (b) will not
disclose Designated Material to any person not authorized by this Order to receive such material;
(c) will not use such Designated Material for any purpose other than this Action; and (d) consent
to the jurisdiction of this Court for any action to enforce the provisions of Exhibit A and this
Order.
b. Counsel for the Party who obtains the signed copies of Exhibit A shall retain them
during this Action.
c. In the event that any person who is required to sign Exhibit A refuses to sign it,
counsel seeking to disclose the Designated Material may seek written permission from the
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Designating Party, or from the Court, to disclose such material to such person upon good cause
shown for such disclosure.
9. Challenging Designations of Confidential or Highly Confidential Discovery Material
a. Any Party may challenge the designation of Discovery Material as Confidential or
Highly Confidential by providing written notice to the Designating Party identifying the
Discovery Material it challenges and the basis for its challenge.
b. Within fourteen (14) calendar days of receiving such notice, the Designating Party
shall meet and confer with the challenging Party in good faith to resolve this dispute. If the
Parties are unable to reach an agreement, within twenty-one (21) calendar days after the meet
and confer, or such other time as the Parties may agree, the challenging Party may file a motion
or other application allowed by the Federal Rules of Civil Procedure, the Local Rules of the
Eastern District of Pennsylvania, and the Court’s Policies and Procedures to challenge the
Confidential or Highly Confidential designation.
c. The challenging Party’s motion or application regarding the challenged material
shall identify with specificity the Confidential or Highly Confidential Discovery Material that is
the subject of the motion, but shall not disclose or reveal the contents of that material except in
the manner prescribed above regarding redactions and sealed filings. If such a motion or
application is made, all Discovery Material so designated shall maintain its existing Confidential
or Highly Confidential status pending a ruling by the Court.
d. The Designating Party retains the burden of establishing the propriety of its
designation of Confidential or Highly Confidential Discovery Material. Nothing in this
paragraph shall limit the right of any Party to petition the Court for an in camera review of the
Discovery Material at issue.
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10. Inadvertent Failure to Designate
a. Except as provided in this paragraph, following a Producing Party’s production or
dissemination of Discovery Material, the inadvertent failure to designate particular Discovery
Material as Confidential or Highly Confidential at the time of production or dissemination shall
not waive the Producing Party’s right to later designate such material as Confidential or Highly
Confidential. Within a reasonable time after making the later designation, the Producing Party
must provide the Receiving Party with a replacement copy of the Discovery Material that is
properly marked Confidential or Highly Confidential in accordance with this Order.
b. No Receiving Party shall be deemed to have violated this Order if, prior to
receiving notification of such later designation, the Receiving Party disclosed such Discovery
Material or used it in a manner inconsistent with the later designation. The Receiving Party shall
notify the Producing Party if any such disclosure had been made prior to its receiving
notification of such later designation.
c. Once such later designation has been made, the relevant documents or materials
shall be treated as Confidential or Highly Confidential in accordance with this Protective Order.
However, if the Discovery Material that inadvertently was not designated is, at the time of the
later designation, already filed with a Court in the public record, the Disclosing Party that failed
to make the designation shall be responsible for moving the Court for appropriate relief, such as
partial redaction or sealing.
d. If an inadvertently omitted Confidential or Highly Confidential designation is first
claimed during the course of a deposition, hearing, or other Court proceeding, the applicable
Discovery Material may be used throughout the deposition, hearing, or Court proceeding as
though no designation had been made, but shall be treated as though such designation had been
made immediately thereafter.
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11. Privileged Material
a. A Party’s inadvertent production or disclosure of Discovery Material covered by
the attorney-client privilege or entitled to work-product protection does not by itself constitute a
waiver of such privilege or protection either in this Action or in any other federal or state
proceeding.
b. If at any time prior to trial a Producing Party discovers that it inadvertently
produced or disclosed Protected Discovery Material, it shall, promptly and in writing or on the
record at a deposition or court hearing, notify the Receiving Party of the inadvertent disclosure.
Upon notice of a claim of inadvertent disclosure, the Receiving Party shall return, sequester,
delete or destroy all copies of the Protected Discovery Material identified in the notice and,
within seven (7) days after receiving notice, provide a written representation to the Producing
Party that all such information was returned, sequestered, deleted or destroyed.
c. To the extent that any discoverable Document is withheld, in whole or in part, for
any reason, including but not limited to any claim of privilege of any kind or work-product
protection, upon the Receiving Party’s notification referenced in the preceding paragraph, the
Producing Party shall within fourteen (14) business days after that notification produce a
privilege log that sets forth the following with respect to every such discoverable Document, if
ascertainable:
i. the nature of the privilege or ground of confidentiality claimed;
ii. the type of document;
iii. the author(s) of the document;
iv. the addressee(s) of the document
v. all persons who received copies of the document;
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vi. the date of the document;
vii. the subject matter of the document;
viii. the existence of any enclosure(s) or attachment(s);
ix. the Bates range of the document; and
Any privilege log or list is to be produced in an Excel spreadsheet or other format capable
of electronic sorting or as otherwise ordered by the Court. The Parties may stipulate to extend the
time periods set forth in this paragraph.
d. If a Receiving Party disputes that the withheld Protected Discovery Material is
entitled to privileged or protected treatment, the Receiving Party must meet and confer with the
Producing Party to discuss the disagreement within fourteen (14) business days of receipt of the
Producing Party’s privilege log described in Section 11.a. After that meet-and-confer, if the
parties still disagree about whether the disclosed Protected Discovery Material is entitled to
privileged or protected treatment, the Receiving Party may move the Court for an Order
compelling production of the documents or information. This motion shall, subject to the Court’s
approval, be filed under seal, if necessary, and shall not assert as a ground for entering such an
Order the fact or circumstances of the production.
e. The Party claiming privilege or work product protection retains the burden of
establishing the privileged or protected nature of any disclosed Protected Discovery Material.
Nothing in this paragraph shall limit the right of any Party or non-party to petition the Court for
an in camera review of the withheld Protected Discovery Material.
f. Notwithstanding the other paragraphs in this Section, the Parties reserve their
rights to petition the Court for a modification of this Order or other appropriate relief in the event
that a Producing Party has engaged in an unreasonable use of the clawback procedure, including
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clawing back documents at unreasonable points in time, at an unreasonable frequency, in an
unreasonable volume, or using the procedure for an improper purpose.
12. Further Requests for Production
a. If, at any time, any Designated Material in the possession, custody, or control of
any person or Party other than the Designating Party is subpoenaed or requested for disclosure to
any court, administrative agency, legislative body, or other person or entity, the person or Party
that received the subpoena or request shall provide prompt written notice of the subpoena or
request to the original Designating Party, provided doing so would not result in violation of any
law or government directive. If the Designating Party wishes to oppose the subpoena or request
for production of such material, the person or Party to whom the subpoena or request is directed
shall not take any position concerning the designation and protection of the Discovery Material.
b. Other than the obligation to comply with the requirements in the paragraph above,
this Order is not intended to affect a person’s or Party’s obligation to respond to such subpoena
or request.
13. Redacting information
A Party may redact responsive documents or information only if the document or
information is subject to a legally recognized claim of privilege or immunity from disclosure.
14. Miscellaneous
a. By this Protective Order, no Party shall be deemed to have waived its right to
assert that any particular Discovery Material should or should not be accorded Confidential or
Highly Confidential treatment or should or should not be subject to attorney-client privilege, the
work product doctrine, or other applicable privilege or protection.
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b. The Parties intend that this Order shall be consistent with the Federal Rules of
Civil Procedure, the Federal Rules of Evidence, any applicable Local Rules of the Eastern
District of Pennsylvania, and the Court’s Policies and Procedures.
c. For purposes of computing any period of time under this Order, the provisions of
Fed. R. Civ. P. 6 and the Local Rules of the Eastern District of Pennsylvania shall apply.
d. This Order does not address, limit, or determine the relevance, discoverability, or
admissibility into evidence of any documents or information.
e. The Parties do not waive any objections as to the production, discoverability,
confidentiality, privilege, or work-product protection of any documents.
f. Any person or Party may challenge the confidentiality designation, privilege, or
work product protection of documents that were, are, or become public knowledge independent
of this Action.
15. Duties Upon Case Termination
a. This Order shall remain in full force and effect and each person or entity subject
to this Order shall continue to be subject to the jurisdiction of this Court, for the purposes of this
Protective Order, in perpetuity. The Court shall not be divested of jurisdiction over any person or
entity, or of the subject matter of this Protective Order, under any circumstances, including the
conclusion of this Action, filing of a notice of appeal, or other pleading which would otherwise
have the effect of divesting the Court of jurisdiction.
b. Within forty-five (45)days after the conclusion of all aspects of this Action,
including any appeals, any Receiving Party that received Designated Materials must either:
i. return such Discovery Materials to the Producing Party; or
ii. certify in writing to counsel for the Producing Party that the Receiving Party
has destroyed all copies of those Discovery Materials containing such
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Confidential or Highly Confidential information in its possession, custody, or
control.
c. Notwithstanding these provisions, Receiving Parties and their counsel shall be
permitted to retain a copy of pleadings, motions, briefs, and other court filings referencing
Confidential or Highly Confidential Discovery Material, subject to the ongoing duty to maintain
the confidentiality of those documents in accordance with this Protective Order, except that
exhibits to court filings that were marked Confidential or Highly Confidential Discovery
Material shall be treated in accordance with paragraph 15.b.
16. Modification of Protective Order Permitted
Any Party, for good cause, may apply to the Court for modification of this Protective
Order. The Parties may also stipulate in writing to amend this Protective Order, subject to Court
approval.
17. Application to Non-Parties
a. Any non-party producing Discovery Material or giving deposition testimony in
this Action may avail themselves of the Confidential or Highly Confidential treatment provided
for in this Protective Order for testimony or Discovery Material by following the procedures
provided herein.
b. Any Party serving a subpoena for documents or testimony shall include with such
subpoena a copy of this Protective Order. All counsel in this Action have the obligation to
inform any non-party that expresses concern or makes inquiry pertaining to issues addressed by
this Protective Order of the existence of this Protective Order and, if requested, to provide a copy
of this Protective Order to such non-party.
c. This Protective Order shall be binding upon non-parties unless they object to it in
writing within ten (10) calendar days of its service upon them.
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BALLARD SPAHR LLP/ BAILEY & GLASSER LLP
/s/ Marcel S. Pratt . /s/ Lawrence J. Lederer
Marcel S. Pratt (Pa. ID 307483 ) Lawrence J. Lederer (Pa. ID 50445)
Michael R. McDonald (Pa. ID 326873) Michael L. Murphy (admitted pro hac vice)
1735 Market Street, 51st Floor Patricia M. Kipnis (Pa. ID 91470)
Philadelphia, PA 19103 Bart D. Cohen (Pa. ID 57606)
T: 215-665-8500 1055 Thomas Jefferson Street NW, Suite 540
F: 215-864-8999 Washington, DC 20007
PrattM@ballardspahr.com T: 202-463-2101
McDonaldM@ballardspahr.com F: 202-463-2103
llederer@baileyglasser.com
Roy Herrera (pro hac vice forthcoming) mmurphy@baileyglasser.com
Daniel A. Arellano (pro hac vice forthcoming) pkipnis@baileyglasser.com
HERRERA ARELLANO LLP bcohen@baileyglasser.com
530 E. McDowell Rd. #107-150
Phoenix, AZ 85004 NOLAN HELLER KAUFFMAN LLP
T: 520-409-4496
roy@ha-firm.com Justin A. Heller (admitted pro hac vice)
daniel@ha-firm.com Matthew M. Zapala (admitted pro hac vice)
80 State Street, 11th Floor
Counsel for Defendant Albany, NY 12207
T: 518-449-3300
jheller@nhkllp.com
mzapala@nhkllp.com
Counsel for Plaintiffs and the Proposed Class
SO ORDERED.
Date: _____________________, 2022
________________________________________
JOHN M. GALLAGHER
UNITED STATES DISTRICT JUDGE
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EXHIBIT A
Case 5:21-cv-04337-JMG Document 19-2 Filed 01/14/22 Page 20 of 20
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF PENNSYLVANIA
ALICIA MARSHALL, DANIEL
PRONSKY, and PARIS TOWNSEND,
individually, and on behalf of all others
Case No. 2:21-cv-04337-JMG
similarly situated,
Plaintiffs,
v.
PRESTAMOS CDFI, LLC,
Defendant.
[PROPOSED] STIPULATED ACKNOWLEDGMENT AND CONSENT
TO BE BOUND BY PROTECTIVE ORDER
I hereby certify that: (i) I have read the Protective Order governing Confidential or
Highly Confidential Discovery Material (the “Protective Order”) entered by the Court in this
action, and I understand its terms; (ii) I understand that Discovery Material designated as
Confidential or Highly Confidential under the Protective Order is being provided to me pursuant
to the terms of the Protective Order; (iii) I agree to be bound by all provisions of the Protective
Order, including its provisions restricting disclosure of material designated as Confidential or
Highly Confidential and limiting the use of such material to the conduct of this action; and (iv) I
hereby submit to the jurisdiction of this Court and the U.S. District Court for the Eastern District
of Pennsylvania for purposes of enforcing the Protective Order.
Dated: ________________________ Signature: __________________________________
Printed Name: _______________________________
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