Preview
Filed: 4/1/2022 9:52 AM
Envelope No. 63173157
CAUSE NO. 20-CV-1458
STACEY DIAMOND AND §
JEFFREY DIAMOND, § IN THE DISTRICT COURT OF
§
Plaintiffs, §
§
§
v. §
§
BRADFORD WOOD COLLIER, § GALVESTON COUNTY, TEXAS
EVERETT FINANCIAL, INC. d/b/a §
SUPREME LENDING, TEXAS §
ALLY REAL ESTATE GROUP, §
LLC, and HENRY ADONIAS PU §
PINEDA §
§ 122ND JUDICIAL DISTRICT
Defendants. §
AGREED PROTECTIVE ORDER
The following procedures shall govern the production and exchange of all documents,
testimony, interrogatories, and other information produced, given, or exchanged by and among
Plaintiffs Stacey and Jeffrey Diamond (“Plaintiffs”) and Defendants Everett Financial, Inc. d/b/a
Supreme Lending (“Supreme Lending”), Bradford Wood Collier (“Collier”), Henry Adonias Pu
Pineda (“Pu”), and Texas Ally Real Estate Group (“Texas Ally”) (collectively, the “Parties”):
Purpose and Scope
1. Discovery in this action may involve disclosure of confidential information, as well
as protected trade secret information. This protective order (“Order”) is therefore entered into
pursuant to the Texas Rules of Civil Procedure and Texas Rules of Evidence to protect against
unauthorized disclosure of any such information and to ensure that such information will be used
only for purposes of this action. All confidential material produced or exchanged in the course of
the above-referenced litigation shall be used solely for the purpose of this litigation.
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2. Confidential treatment may be claimed for documents, depositions, and other
discovery materials, and any portions or summaries of such material (“Confidential Documents”
or “Confidential Material”). The responding party shall designate any other documents and
information it considers to be confidential.
Designation of Materials
3. The producing parties may designate any Confidential Material as “Confidential”
or “Attorneys Eyes Only” when a party, third-party, or their counsel in good faith believes that
such Confidential Material constitutes or reveals personal, financial and/or trade secret information
that is not generally available to the public. For the purposes of this Order, information considered
to be Confidential Material includes, but is not limited to, all non-public materials containing
information related to the following: policies and procedures regarding borrower applications,
underwriting, servicing and/or lending practices by Supreme Lending.
4. Confidential treatment may be claimed for Confidential Material by:
(a) In the case of Confidential Documents produced at deposition, by stating on
the record a description of the documents, including exhibit number and
identification number (Bates number), if any.
(b) In the case of other documents, stamping in bold black or red ink,
“CONFIDENTIAL” or “ATTORNEYS EYES ONLY” on the document,
or by providing counsel for the opposing party with a reasonably detailed
written description of the documents (including Bates number, if
applicable). Such designation shall normally be accomplished prior to the
production of documents, and in any event, must be made no later than thirty
(30) days after production.
(c) In the case of depositions, by designation of the deposition (or the
appropriate portion of the deposition) as confidential. Such designation
shall be done by counsel on the record.
(d) In the case of summaries, excerpts, or exhibits prepared from Confidential
Material, the party preparing same shall be responsible for maintaining the
confidentiality of said document(s).
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5. It shall be the duty of the party or third-party who seeks to invoke protection under
this Order to give notice, in the manner set forth herein, of the Confidential Discovery material to
be covered hereby, and the level of confidentiality invoked. The duty of the other parties and of
all persons bound by this Order to maintain confidentiality hereunder shall commence with such
notice.
6. The designation of Confidential Material need not be made until copies of the
Material are requested by the party to receive them.
Disclosure
7. Documents and information designated as “Confidential” or “AEO” shall not be
disclosed directly or indirectly by any person receiving such materials to persons other than the
following persons (“Qualified Persons”), as to whom disclosure shall be limited solely to the extent
reasonably necessary for the prosecution, defense, and/or appeal of this action:
(a) The Court, persons employed by the Court, and stenographers transcribing
the testimony or argument at a hearing, trial, or deposition in this action or
any appeal therefrom;
(b) Counsel for the parties in this action, whether or not counsel of record,
including in-house counsel, associates, legal assistants, paralegals,
secretarial and clerical employees, and outside copy services, litigation
consulting services, document management services, and graphic services
that are assisting counsel in the prosecution, defense, and/or appeal of this
action;
(c) Independent experts, consultants and/or investigators retained, employed,
or informally consulted by counsel in connection with the prosecution,
defense, and/or appeal of this action, including their secretarial and clerical
employees who are assisting in the prosecution, defense, and/or appeal of
this action;
(d) The parties and the officers and employees of any party solely for the
purpose of prosecuting, defending, and/or appealing this litigation;
(e) Auditors, accountants, regulators, and reinsurers not assisting in the
prosecution or defense of a party’s claims or defenses in the lawsuit but who
may require access to Confidential Material as authorized by statute,
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4871-3341-5958.1
regulation, contract, or as necessary in the regular course of business of a
party; and
(f) Fact witnesses during depositions. Absent the parties’ agreement, third-
party fact witnesses may not retain Confidential Material.
8. Any Qualified Person in category (c) above who is given access to Confidential
Material shall, prior to being given such material, be informed of the provisions of this Order, read
this Order, and execute a sworn undertaking, in the form annexed hereto as Exhibit A, indicating
that he/she has read this Order and will abide by its terms. The original of such sworn statements
shall be retained by counsel for each party who intends to or does provide such Qualified Persons
any such material, until the conclusion of this action, including all appeals. If requested upon the
conclusion of this action, counsel for each party shall serve a copy of such statements upon counsel
for each other party. The parties agree not to use these statements for any purpose other than
monitoring and enforcing compliance with this Order.
Additional Provisions
10. Counsel shall attempt, in good faith, to resolve any disputes regarding the propriety
and terms of disclosure on an informal basis (without the Court’s intervention). However, if any
party believes any material that has been designated “Confidential” is not properly subject to the
confidentiality provisions of this Order, that party must first give seven (7) days notice to the party
claiming confidentiality. If no or a negative response is received, that party may file a motion with
the Court requesting that the Material be de-designated, re-designated, and/or exempted from the
terms of this Order. The party which so designated such Material (the “designating party”) must
then file a response to the motion as required by the rules and shall bear the burden of justifying
confidential treatment of the disputed Material under applicable law. The protection afforded by
this Order shall continue until a decision on the motion is made by the Court. If no response to the
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4871-3341-5958.1
motion is timely filed and served on counsel for all parties, the protection afforded Confidential
Material by this Order shall terminate as to the Material described in the moving party’s motion.
11. Prior to using any Confidential Material in trial, the receiving party shall give the
disclosing party reasonable (in no event, less than 14 days) notice of its intent to use the
Confidential Material so that appropriate measures may be employed to protect the confidential
nature of the information contained therein.
12. The inadvertent or unintentional disclosure of Material marked “Confidential” by
counsel or other person(s) shall not be a reason for the imposition of sanctions pursuant to this
Agreed Protective Order/Confidentiality Agreement. Upon discovery of the inadvertent or
unintentional disclosure of Confidential Material, counsel shall immediately notify counsel
representing the party whose Confidential Material has been disclosed. Such notice shall describe
with particularity, to the extent known and reasonably possible, the Confidential Material which
has been disclosed (including Bates number, if applicable) and the identity (name, title, address
and telephone number) of the person(s) to whom the disclosure was made.
13. The inadvertent or unintentional disclosure by the responding party of Confidential
Material, regardless of whether the material was so-designated at the time of disclosure, shall not
be deemed a waiver, in whole or in part, of a party’s claim of confidentiality, either as to the
specific material disclosed or as to any other material relating thereto or on the same or related
subject matter.
14. A party shall not be obligated to challenge the propriety of a confidentiality
designation at the time made, and a failure to do so shall not preclude a subsequent challenge
thereto.
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4871-3341-5958.1
15. Nothing in this Agreed Protective Order/Confidentiality Agreement shall bar or
otherwise restrict any attorney herein from rendering advice to his client with respect to this
litigation and, in the course thereof, relying in a general way upon his examination of Confidential
Material produced or exchanged herein.
16. In the event this litigation is concluded by any means, including judgment or
settlement and dismissal, the parties shall return or destroy Confidential Material (including all
copies thereof) upon written request submitted by counsel for the party producing such
Confidential Material.
17. This document and all provisions contained herein are applicable from the date of
the filing of same with the court, forward, and shall not be applied retroactive to anything prior to
said date.
SIGNED AND ENTERED on this ____ day of ___________________, 2022.
JUDGE PRESIDING
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4871-3341-5958.1
AGREED TO AS TO FORM AND SUBSTANCE:
BRADLEY ARANT BOULT CUMMINGS LLP
/s/ Gabriella E. Alonso
Gabriella E. Alonso
Texas Bar No. 24113527
galonso@bradley.com
Robert H. Ford
Texas Bar No. 24074219
rford@bradley.com
600 Travis, Suite 4800
Houston, Texas 77002
Telephone: 713-576-0300
Facsimile: 713-576-0301
Keith S. Anderson
Texas Bar No. 24075789
One Federal Place
1819 Fifth Avenue North
Birmingham, Alabama 35203
(205) 521-8000 Telephone
(205) 488-6714 Telecopier
ATTORNEYS FOR DEFENDANT
EVERETT FINANCIAL, INC. D/B/A
SUPREME LENDING
J. DIAMOND AND ASSOCIATES, PLLC
/s/ Carla C. Courtney (with permission)
Carla S. Courtney
carla@jdiamondandassociates.com
Texas Bar No. 24115455
Taylor Diamond
taylor@jdiamondandassociates.com
Texas Bar No. 24109809
730 North Loop
Houston, Texas 77009
Telephone: (713) 227-6800
Facsimile: (713) 227-6801
ATTORNEYS FOR PLAINTIFFS
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4871-3341-5958.1
SHEINNESS GLOVER & GROSSMAN, LLP
/s/ Steven D. Grossman (with permission)
Steven D. Grossman
Texas Bar No. 08547800
sgrossman@hou-law.com
4544 Post Oak Place Dr., Ste. 270
Houston, Texas 77027
Telephone: (713) 374-7015
Facsimile: (713) 374-7049
ATTORNEY FOR DEFENDANTS
BRADFORD COLLIER AND HENRY
ADONIAS PU PINEDA
GAUNTT, KOEN, BINNEY & KIDD, LLP
/s/ Tom O’Connell (with permission)
Tom O’Connell
Texas Bar No. 15180700
Tom.oconnell@gkbklaw.com
25700 I-45 North, Ste. 130
Spring, Texas 77386
Telephone: (281) 367-6555
Facsimile: (281) 367-3705
ATTORNEY FOR DEFENDANT
TEXAS ALLY REAL ESTATE GROUP,
LLC
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4871-3341-5958.1
EXHIBIT A
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4871-3341-5958.1
CAUSE NO. 20-CV-1458
STACEY DIAMOND AND § IN THE DISTRICT COURT OF
JEFFREY DIAMOND, §
§
Plaintiffs, §
§
v. §
§
BRADFORD WOOD COLLIER, § GALVESTON COUNTY, TEXAS
EVERETT FINANCIAL, INC. §
d/b/a SUPREME LENDING, §
TEXAS ALLY REAL ESTATE §
GROUP, LLC, and HENRY §
ADONIAS PU PINEDA §
§
Defendants. § 122ND JUDICIAL DISTRICT
The undersigned has read the Agreed Protective Order, understands its contents, and
hereby undertakes to make no disclosures of “Confidential” Discovery Material to any person who
is not permitted to have access to “Confidential” Discovery Material by this Order, as applicable.
In addition, the undersigned agrees not to use “Confidential” Discovery Material for any purpose
whatsoever other than in connection with this litigation or its potential resolution through business
negotiations between the parties.
The undersigned further understands that a violation of this undertaking could be
punishable as a contempt of court and hereby submits to the jurisdiction of the Court for purposes
of enforcement of the Agreed Protective Order.
Date: Name:_________________________________
Sworn to and subscribed before me this ____ day of _______________, 2022.
NOTARY PUBLIC
My Commission Expires:
10
4871-3341-5958.1
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Angela Davis on behalf of Gabriella Alonso
Bar No. 24113527
adavis@bradley.com
Envelope ID: 63173157
Status as of 4/1/2022 9:54 AM CST
Associated Case Party: Texas Ally Real Estate Group, LLC
Name BarNumber Email TimestampSubmitted Status
Thomas FO'Connell tom.oconnell@gkbwklaw.com 4/1/2022 9:52:13 AM SENT
Tonya Brantley tonya.brantley@gkbklaw.com 4/1/2022 9:52:13 AM SENT
Associated Case Party: BradfordWoodCollier
Name BarNumber Email TimestampSubmitted Status
Steven D.Grossman sgrossman@hou-law.com 4/1/2022 9:52:13 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Keith Anderson 24075789 kanderson@bradley.com 4/1/2022 9:52:13 AM SENT
Robert Ford 24074219 rford@bradley.com 4/1/2022 9:52:13 AM SENT
Gabriella Alonso 24113527 galonso@bradley.com 4/1/2022 9:52:13 AM SENT
Cindy Lopez clopez@bradley.com 4/1/2022 9:52:13 AM SENT
Angela Davis adavis@bradley.com 4/1/2022 9:52:13 AM SENT
Taylor Diamond taylor@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Carla S.Courtney carla@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Laura Garcia JDAP013@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Adaly Rendon adaly.rendon@bradley.com 4/1/2022 9:52:13 AM SENT
Rebeka Harricharran jdap4@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Associated Case Party: Stacey Diamond
Name
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Angela Davis on behalf of Gabriella Alonso
Bar No. 24113527
adavis@bradley.com
Envelope ID: 63173157
Status as of 4/1/2022 9:54 AM CST
Associated Case Party: Stacey Diamond
Taylor Diamond 24109809 service@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Alyssa Gibson JDAP013@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT
Preview
Filed: 4/1/2022 9:52 AM Envelope No. 63173157 CAUSE NO. 20-CV-1458 STACEY DIAMOND AND § JEFFREY DIAMOND, § IN THE DISTRICT COURT OF § Plaintiffs, § § § v. § § BRADFORD WOOD COLLIER, § GALVESTON COUNTY, TEXAS EVERETT FINANCIAL, INC. d/b/a § SUPREME LENDING, TEXAS § ALLY REAL ESTATE GROUP, § LLC, and HENRY ADONIAS PU § PINEDA § § 122ND JUDICIAL DISTRICT Defendants. § AGREED PROTECTIVE ORDER The following procedures shall govern the production and exchange of all documents, testimony, interrogatories, and other information produced, given, or exchanged by and among Plaintiffs Stacey and Jeffrey Diamond (“Plaintiffs”) and Defendants Everett Financial, Inc. d/b/a Supreme Lending (“Supreme Lending”), Bradford Wood Collier (“Collier”), Henry Adonias Pu Pineda (“Pu”), and Texas Ally Real Estate Group (“Texas Ally”) (collectively, the “Parties”): Purpose and Scope 1. Discovery in this action may involve disclosure of confidential information, as well as protected trade secret information. This protective order (“Order”) is therefore entered into pursuant to the Texas Rules of Civil Procedure and Texas Rules of Evidence to protect against unauthorized disclosure of any such information and to ensure that such information will be used only for purposes of this action. All confidential material produced or exchanged in the course of the above-referenced litigation shall be used solely for the purpose of this litigation. 1 4871-3341-5958.1 2. Confidential treatment may be claimed for documents, depositions, and other discovery materials, and any portions or summaries of such material (“Confidential Documents” or “Confidential Material”). The responding party shall designate any other documents and information it considers to be confidential. Designation of Materials 3. The producing parties may designate any Confidential Material as “Confidential” or “Attorneys Eyes Only” when a party, third-party, or their counsel in good faith believes that such Confidential Material constitutes or reveals personal, financial and/or trade secret information that is not generally available to the public. For the purposes of this Order, information considered to be Confidential Material includes, but is not limited to, all non-public materials containing information related to the following: policies and procedures regarding borrower applications, underwriting, servicing and/or lending practices by Supreme Lending. 4. Confidential treatment may be claimed for Confidential Material by: (a) In the case of Confidential Documents produced at deposition, by stating on the record a description of the documents, including exhibit number and identification number (Bates number), if any. (b) In the case of other documents, stamping in bold black or red ink, “CONFIDENTIAL” or “ATTORNEYS EYES ONLY” on the document, or by providing counsel for the opposing party with a reasonably detailed written description of the documents (including Bates number, if applicable). Such designation shall normally be accomplished prior to the production of documents, and in any event, must be made no later than thirty (30) days after production. (c) In the case of depositions, by designation of the deposition (or the appropriate portion of the deposition) as confidential. Such designation shall be done by counsel on the record. (d) In the case of summaries, excerpts, or exhibits prepared from Confidential Material, the party preparing same shall be responsible for maintaining the confidentiality of said document(s). 2 4871-3341-5958.1 5. It shall be the duty of the party or third-party who seeks to invoke protection under this Order to give notice, in the manner set forth herein, of the Confidential Discovery material to be covered hereby, and the level of confidentiality invoked. The duty of the other parties and of all persons bound by this Order to maintain confidentiality hereunder shall commence with such notice. 6. The designation of Confidential Material need not be made until copies of the Material are requested by the party to receive them. Disclosure 7. Documents and information designated as “Confidential” or “AEO” shall not be disclosed directly or indirectly by any person receiving such materials to persons other than the following persons (“Qualified Persons”), as to whom disclosure shall be limited solely to the extent reasonably necessary for the prosecution, defense, and/or appeal of this action: (a) The Court, persons employed by the Court, and stenographers transcribing the testimony or argument at a hearing, trial, or deposition in this action or any appeal therefrom; (b) Counsel for the parties in this action, whether or not counsel of record, including in-house counsel, associates, legal assistants, paralegals, secretarial and clerical employees, and outside copy services, litigation consulting services, document management services, and graphic services that are assisting counsel in the prosecution, defense, and/or appeal of this action; (c) Independent experts, consultants and/or investigators retained, employed, or informally consulted by counsel in connection with the prosecution, defense, and/or appeal of this action, including their secretarial and clerical employees who are assisting in the prosecution, defense, and/or appeal of this action; (d) The parties and the officers and employees of any party solely for the purpose of prosecuting, defending, and/or appealing this litigation; (e) Auditors, accountants, regulators, and reinsurers not assisting in the prosecution or defense of a party’s claims or defenses in the lawsuit but who may require access to Confidential Material as authorized by statute, 3 4871-3341-5958.1 regulation, contract, or as necessary in the regular course of business of a party; and (f) Fact witnesses during depositions. Absent the parties’ agreement, third- party fact witnesses may not retain Confidential Material. 8. Any Qualified Person in category (c) above who is given access to Confidential Material shall, prior to being given such material, be informed of the provisions of this Order, read this Order, and execute a sworn undertaking, in the form annexed hereto as Exhibit A, indicating that he/she has read this Order and will abide by its terms. The original of such sworn statements shall be retained by counsel for each party who intends to or does provide such Qualified Persons any such material, until the conclusion of this action, including all appeals. If requested upon the conclusion of this action, counsel for each party shall serve a copy of such statements upon counsel for each other party. The parties agree not to use these statements for any purpose other than monitoring and enforcing compliance with this Order. Additional Provisions 10. Counsel shall attempt, in good faith, to resolve any disputes regarding the propriety and terms of disclosure on an informal basis (without the Court’s intervention). However, if any party believes any material that has been designated “Confidential” is not properly subject to the confidentiality provisions of this Order, that party must first give seven (7) days notice to the party claiming confidentiality. If no or a negative response is received, that party may file a motion with the Court requesting that the Material be de-designated, re-designated, and/or exempted from the terms of this Order. The party which so designated such Material (the “designating party”) must then file a response to the motion as required by the rules and shall bear the burden of justifying confidential treatment of the disputed Material under applicable law. The protection afforded by this Order shall continue until a decision on the motion is made by the Court. If no response to the 4 4871-3341-5958.1 motion is timely filed and served on counsel for all parties, the protection afforded Confidential Material by this Order shall terminate as to the Material described in the moving party’s motion. 11. Prior to using any Confidential Material in trial, the receiving party shall give the disclosing party reasonable (in no event, less than 14 days) notice of its intent to use the Confidential Material so that appropriate measures may be employed to protect the confidential nature of the information contained therein. 12. The inadvertent or unintentional disclosure of Material marked “Confidential” by counsel or other person(s) shall not be a reason for the imposition of sanctions pursuant to this Agreed Protective Order/Confidentiality Agreement. Upon discovery of the inadvertent or unintentional disclosure of Confidential Material, counsel shall immediately notify counsel representing the party whose Confidential Material has been disclosed. Such notice shall describe with particularity, to the extent known and reasonably possible, the Confidential Material which has been disclosed (including Bates number, if applicable) and the identity (name, title, address and telephone number) of the person(s) to whom the disclosure was made. 13. The inadvertent or unintentional disclosure by the responding party of Confidential Material, regardless of whether the material was so-designated at the time of disclosure, shall not be deemed a waiver, in whole or in part, of a party’s claim of confidentiality, either as to the specific material disclosed or as to any other material relating thereto or on the same or related subject matter. 14. A party shall not be obligated to challenge the propriety of a confidentiality designation at the time made, and a failure to do so shall not preclude a subsequent challenge thereto. 5 4871-3341-5958.1 15. Nothing in this Agreed Protective Order/Confidentiality Agreement shall bar or otherwise restrict any attorney herein from rendering advice to his client with respect to this litigation and, in the course thereof, relying in a general way upon his examination of Confidential Material produced or exchanged herein. 16. In the event this litigation is concluded by any means, including judgment or settlement and dismissal, the parties shall return or destroy Confidential Material (including all copies thereof) upon written request submitted by counsel for the party producing such Confidential Material. 17. This document and all provisions contained herein are applicable from the date of the filing of same with the court, forward, and shall not be applied retroactive to anything prior to said date. SIGNED AND ENTERED on this ____ day of ___________________, 2022. JUDGE PRESIDING 6 4871-3341-5958.1 AGREED TO AS TO FORM AND SUBSTANCE: BRADLEY ARANT BOULT CUMMINGS LLP /s/ Gabriella E. Alonso Gabriella E. Alonso Texas Bar No. 24113527 galonso@bradley.com Robert H. Ford Texas Bar No. 24074219 rford@bradley.com 600 Travis, Suite 4800 Houston, Texas 77002 Telephone: 713-576-0300 Facsimile: 713-576-0301 Keith S. Anderson Texas Bar No. 24075789 One Federal Place 1819 Fifth Avenue North Birmingham, Alabama 35203 (205) 521-8000 Telephone (205) 488-6714 Telecopier ATTORNEYS FOR DEFENDANT EVERETT FINANCIAL, INC. D/B/A SUPREME LENDING J. DIAMOND AND ASSOCIATES, PLLC /s/ Carla C. Courtney (with permission) Carla S. Courtney carla@jdiamondandassociates.com Texas Bar No. 24115455 Taylor Diamond taylor@jdiamondandassociates.com Texas Bar No. 24109809 730 North Loop Houston, Texas 77009 Telephone: (713) 227-6800 Facsimile: (713) 227-6801 ATTORNEYS FOR PLAINTIFFS 7 4871-3341-5958.1 SHEINNESS GLOVER & GROSSMAN, LLP /s/ Steven D. Grossman (with permission) Steven D. Grossman Texas Bar No. 08547800 sgrossman@hou-law.com 4544 Post Oak Place Dr., Ste. 270 Houston, Texas 77027 Telephone: (713) 374-7015 Facsimile: (713) 374-7049 ATTORNEY FOR DEFENDANTS BRADFORD COLLIER AND HENRY ADONIAS PU PINEDA GAUNTT, KOEN, BINNEY & KIDD, LLP /s/ Tom O’Connell (with permission) Tom O’Connell Texas Bar No. 15180700 Tom.oconnell@gkbklaw.com 25700 I-45 North, Ste. 130 Spring, Texas 77386 Telephone: (281) 367-6555 Facsimile: (281) 367-3705 ATTORNEY FOR DEFENDANT TEXAS ALLY REAL ESTATE GROUP, LLC 8 4871-3341-5958.1 EXHIBIT A 9 4871-3341-5958.1 CAUSE NO. 20-CV-1458 STACEY DIAMOND AND § IN THE DISTRICT COURT OF JEFFREY DIAMOND, § § Plaintiffs, § § v. § § BRADFORD WOOD COLLIER, § GALVESTON COUNTY, TEXAS EVERETT FINANCIAL, INC. § d/b/a SUPREME LENDING, § TEXAS ALLY REAL ESTATE § GROUP, LLC, and HENRY § ADONIAS PU PINEDA § § Defendants. § 122ND JUDICIAL DISTRICT The undersigned has read the Agreed Protective Order, understands its contents, and hereby undertakes to make no disclosures of “Confidential” Discovery Material to any person who is not permitted to have access to “Confidential” Discovery Material by this Order, as applicable. In addition, the undersigned agrees not to use “Confidential” Discovery Material for any purpose whatsoever other than in connection with this litigation or its potential resolution through business negotiations between the parties. The undersigned further understands that a violation of this undertaking could be punishable as a contempt of court and hereby submits to the jurisdiction of the Court for purposes of enforcement of the Agreed Protective Order. Date: Name:_________________________________ Sworn to and subscribed before me this ____ day of _______________, 2022. NOTARY PUBLIC My Commission Expires: 10 4871-3341-5958.1 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Angela Davis on behalf of Gabriella Alonso Bar No. 24113527 adavis@bradley.com Envelope ID: 63173157 Status as of 4/1/2022 9:54 AM CST Associated Case Party: Texas Ally Real Estate Group, LLC Name BarNumber Email TimestampSubmitted Status Thomas FO'Connell tom.oconnell@gkbwklaw.com 4/1/2022 9:52:13 AM SENT Tonya Brantley tonya.brantley@gkbklaw.com 4/1/2022 9:52:13 AM SENT Associated Case Party: BradfordWoodCollier Name BarNumber Email TimestampSubmitted Status Steven D.Grossman sgrossman@hou-law.com 4/1/2022 9:52:13 AM SENT Case Contacts Name BarNumber Email TimestampSubmitted Status Keith Anderson 24075789 kanderson@bradley.com 4/1/2022 9:52:13 AM SENT Robert Ford 24074219 rford@bradley.com 4/1/2022 9:52:13 AM SENT Gabriella Alonso 24113527 galonso@bradley.com 4/1/2022 9:52:13 AM SENT Cindy Lopez clopez@bradley.com 4/1/2022 9:52:13 AM SENT Angela Davis adavis@bradley.com 4/1/2022 9:52:13 AM SENT Taylor Diamond taylor@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT Carla S.Courtney carla@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT Laura Garcia JDAP013@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT Adaly Rendon adaly.rendon@bradley.com 4/1/2022 9:52:13 AM SENT Rebeka Harricharran jdap4@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT Associated Case Party: Stacey Diamond Name Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Angela Davis on behalf of Gabriella Alonso Bar No. 24113527 adavis@bradley.com Envelope ID: 63173157 Status as of 4/1/2022 9:54 AM CST Associated Case Party: Stacey Diamond Taylor Diamond 24109809 service@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT Alyssa Gibson JDAP013@jdiamondandassociates.com 4/1/2022 9:52:13 AM SENT