711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 1 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

Milo Petranovich, OSB No. 813376

petranovichm@lanepowell.com

Peter D. Hawkes, OSB No. 071986

hawkesp@lanepowell.com

SreeVamshi C. Reddy, OSB No. 140560

reddyv@lanepowell.com

LANE POWELL PC

601 SW Second Avenue, Suite 2100

Portland, Oregon 97204-3158

Telephone: 503.778.2114

Attorneys for Defendant Integrity Bank & Trust

UNITED STATES DISTRICT COURT

DISTRICT OF OREGON

PORTLAND DIVISION

LAWRENCE P. CIUFFITELLI, for himself 

and as Trustee of CIUFFITELLI 

REVOCABLE TRUST; GREG and ANGELA 

JULIEN; JAMES and SUSAN 

MACDONALD, as Co-Trustees of the

MACDONALD FAMILY TRUST; R.F. 

MACDONALD CO.; ANDREW NOWAK, for 

himself and as Trustee of the ANDREW 

NOWAK REVOCABLE LIVING TRUST 

U/A 2/20/2002; WILLIAM RAMSTEIN; and

GREG WARRICK, for himself and, with

SUSAN WARRICK, as Co-Trustees of the

WARRICK FAMILY TRUST, individually 

and on behalf of all others similarly situated,

Plaintiffs,

v.

DELOITTE & TOUCHE LLP; 

EISNERAMPER LLP; SIDLEY AUSTIN 

LLP; TONKON TORP LLP; TD 

AMERITRADE, INC.; and INTEGRITY 

BANK & TRUST,

Defendants.

Case No. 3:16-cv-00580-AC

Defendant Integrity Bank & Trust’s

OBJECTIONS TO THE FEBRUARY 21, 

2017 OPINION AND ORDER OF 

MAGISTRATE JUDGE

(ORAL ARGUMENT REQUESTED)

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 1 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 2 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

I. LOCAL RULE 7-1 CERTIFICATION

Pursuant to L.R. 7.1(a), counsel for defendant Integrity Bank & Trust (“Integrity”) has 

conferred by telephone with counsel for plaintiffs in good faith regarding discovery, but the parties 

have been unable to agree on the proper scope or sequence of discovery.

II. MOTION

Pursuant to 28 U.S.C. § 636(b)(1)(A) and Rule 72(a) of the Federal Rules of Civil 

Procedure, Integrity moves for an order reviewing and vacating Magistrate Judge Acosta’s 

February 21, 2017 Opinion and Order (ECF No. 213), which granted in part and denied in part 

Integrity’s Motion for a Protective Order in the above-captioned matter. Alternatively, Integrity 

respectfully requests that the Court recommit this dispute to Magistrate Judge Acosta for 

clarification regarding the scope of the Court’s rulings in the February 21, 2017 Opinion and Order.

III. RELEVANT FACTUAL BACKGROUND

Integrity sets forth below only those facts necessary to provide context for the instant

motion. A more detailed recitation of the relevant facts is contained in the pleadings accompanying

the instant motion.

A. Plaintiffs’ Claims and Integrity’s Motion to Dismiss.

Plaintiffs filed a First Amended Complaint (hereinafter “FAC” or the “Complaint”) against 

Integrity, naming Integrity as a defendant in this putative class action for the first time, on May 

19, 2016. (ECF No. 57.) As set forth in Integrity’s Motion to Dismiss Plaintiffs’ First Amended 

Complaint (ECF No. 95) and Integrity’s Reply Memorandum to the Motion to Dismiss

(ECF No. 135), both of which are attached hereto,1 the claims against Integrity in Plaintiffs’ First 

Amended Complaint can be reduced to three allegations: (1) Integrity served as the custodian for 

certain Aequitas2 fundraising entities; (2) Integrity solicited the sale of certain Aequitas 

 1

 As Exhibit 1 and Exhibit 2 to the Declaration of Milo Petranovich (hereinafter “Petranovich 

Decl.” or “Petranovich Declaration”).

2 Plaintiffs use the term “Aequitas” throughout the First Amended Complaint to refer to several 

different and legally distinct “Aequitas” entities. Likewise, Plaintiffs refer generically to 

“Aequitas securities” throughout the Complaint, rather than to the specific, legally distinct

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 2 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 3 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

Commercial Finance, LLC (“ACF”) notes, though any such transaction is not identified with any 

specificity in the First Amended Complaint; and (3) Integrity solicited the sale of certain Aequitas 

Income Opportunity Fund II, LLC (“AIOF-II”) notes, including those sold to certain trustees of 

the Warrick Family Trust in or about September 2015. (See FAC ¶¶ 30(f), 36, 55, 70.) 

Although Plaintiffs summarily allege in the Complaint that Integrity “participated” and 

“materially aided” in the sale of “Aequitas securities,” Plaintiffs offer no factual or legal support 

under the Oregon Securities Law for their conclusory allegations. Notably, Plaintiffs’ First 

Amended Complaint contains only two named plaintiffs with any connection to Integrity – Greg 

Warrick, individually, and Greg and Susan Warrick, acting as co-trustees of the Warrick Family 

Trust.

Plaintiffs’ vague allegations in the Complaint do not, as a matter of law, state a claim 

against Integrity – indeed, Plaintiffs concede as much in their Opposition to Integrity’s Motion to 

Dismiss (ECF No. 125) when they offer four pages of additional factual allegations which appear 

nowhere in the First Amended Complaint.

B. Plaintiffs’ Document Requests.

Despite the skeletal allegations contained in the Complaint with respect to Integrity, on 

September 29, 2016, Plaintiffs served their extensive First Requests for Production of Documents

on Integrity (hereinafter, “Plaintiffs’ RFPs” or the “Document Requests”), attached as Exhibit 3 to 

the Petranovich Declaration. Plaintiffs’ RFPs contain thirty-six (36) individual requests, most of 

which are burdensome, overly broad, irrelevant and disproportionate to the needs of this litigation, 

particularly at this stage. Plaintiffs have attempted, unsuccessfully, to plead a secondary liability 

claim against Integrity with respect to two named plaintiffs, and yet they seek what amounts to 

full merits-based discovery for a certified class action. 

 

“Aequitas” entity whose sales/offerings of securities are alleged to be at issue. By utilizing 

Plaintiffs’ terms for the purposes of this motion, Integrity does not concede that the securities 

referenced as “Aequitas securities” in the Complaint were issued by a single “Aequitas” entity or 

that the individual securities offerings/sales should be analyzed as a whole with respect to 

Plaintiffs’ claims.

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 3 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 4 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

Notably, Plaintiffs’ Document Requests require production of ESI, with extensive 

instructions and guidelines regarding the type and manner of production, despite the fact that the 

Parties agreed, when they filed their Joint Report of Parties’ F.R.C.P. 26(f) Conference with the 

Court on November 2, 2016 (ECF No. 163 (hereinafter the “Joint Report”) that “production of ESI 

is not appropriate at this time * * * [and] to discuss such issues in conjunction with the production 

of ESI in due course.” (Joint Report at 7.)

C. Defendant Integrity’s Motion for Protective Order.

On November 28, 2016, Integrity filed a Motion for Protective Order and Supporting 

Memorandum (ECF No. 175), requesting that the Court issue a protective order against Plaintiffs’ 

RFPs, pending: 

(i) disposition of Integrity’s Motion to Dismiss Plaintiffs’ First 

Amended Complaint, (ECF Nos. 95 and 135), and the Joint Motion 

to Dismiss the First Amended Complaint, (ECF No. 74) (“Joint 

Motion”), and (ii) the lifting of the discovery stay in the SEC action. 

Alternatively, Integrity moves to limit plaintiffs’ discovery to those 

documents to be produced under its Response to Plaintiffs’ First 

Request for Production, pending (i) and (ii) above.

(Integrity’s Mot. for Prot. Order at 2, attached as Exhibit 4 to Petranovich Decl.)

Integrity set forth a number of reasons why a stay of discovery would be appropriate, 

including the pending motions to dismiss, the stay of discovery in the SEC Receivership action 

and the inevitably imminent filing of a second amended complaint. (Id. at 3-7.) Integrity also 

requested, in the alternative, that discovery be limited to “the documents Integrity has agreed to 

produce in its Response to Plaintiffs’ First Requests for Production of Documents, essentially all 

the documents in Integrity’s customer files of those two named plaintiffs in the First Amended 

Complaint (“FAC”) who were customers of Integrity,” and that ESI be excluded. (Id. at 3, 7.) 

Integrity noted that the Document Requests are “overbroad and disproportionate to the 

claim in this case” under the plain language of Rule 26 of the Federal Rules of Civil Procedure 

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 4 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 5 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

(“Rule 26”) and the recent amendment thereto,

3 and premised on a faulty reading of the reach of 

the Oregon Securities Law, the requirements of federal pleading and the scope of reasonable 

discovery in light thereof. (Id. at 7.)

D. Magistrate Judge Acosta’s February 21, 2017 Opinion & Order.

Magistrate Judge Acosta granted in part and denied in part Integrity’s Motion for a 

Protective Order by Opinion and Order issued on February 21, 2017. (ECF No. 213, attached as 

Exhibit 5 to Petranovich Decl. (hereinafter “February 2017 Opinion and Order”).) The February 

2017 Opinion and Order cross-references and incorporates the Opinion and Order issued by 

Magistrate Judge Acosta on November 28, 2016, in which the Court granted in part and denied in 

part defendant Deloitte & Touche LLP’s and defendant EisnerAmper LLP’s motions for a 

protective order. (ECF No. 174, attached as Exhibit 6 to Petranovich Decl. (hereinafter “November 

2016 Opinion and Order”).)

In the February 2017 Opinion and Order, Magistrate Judge Acosta outlines the Moving 

Defendants’ positions, in relevant part, as follows: 

In their respective motions, each of the Moving Defendants

primarily argue they should not be required to undertake the 

expensive, burdensome, and time-consuming discovery Plaintiffs 

request until after the court decides whether Plaintiffs have pleaded

a viable claim for relief against them. Each of the Moving 

Defendants also argues that discovery should not occur because a 

discovery stay has been entered in Securities and Exchange 

Commission v. Aequitas Management, LLC, et al., Case No. 3: l 6-

 3 Rule 26 provides, in relevant part:

Unless otherwise limited by court order, the scope of discovery is as 

follows: Parties may obtain discovery regarding any nonprivileged 

matter that is relevant to any party’s claim or defense and 

proportional to the needs of the case, considering the importance of 

the issues at stake in the action, the amount in controversy, the 

parties’ relative access to relevant information, the parties’ 

resources, the importance of the discovery in resolving the issues, 

and whether the burden or expense of the proposed discovery 

outweighs its likely benefit. Information within this scope of 

discovery need not be admissible in evidence to be discoverable.

(Emphasis added).

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 5 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 6 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

cv-00438-PK (“SEC case”), which stay enjoins “all discovery 

directed to the Receiver and the Receivership Entity” and thus 

applies to all Aequitas companies and its affiliates. 

(See ECF No. 156, filed April 14, 2016.)

(Feb. 2017 Opinion and Order at 5.)

The Court, again, sets forth the “Purpose of the Moving Defendants’ Motions” as follows:

As did the Accounting Firms through their motions for protective 

order, the Moving Defendants here seek a stay of discovery because 

they believe their pending motions to dismiss will dispose of 

Plaintiffs’ claim.

(Feb. 2017 Opinion and Order at 7-8 (emphasis added).) Critically, the Court does not address in 

either of these sections of its Opinion and Order that Integrity also sought relief in the alternative 

to a discovery stay, in the form of a limitation on discovery pursuant to the proportionality standard 

set forth in Rule 26(b)(1). (Integrity’s Mot. for Prot. Order at 3, 7.) The expansive scope of 

Plaintiffs’ Document Requests would necessarily encompass information that is not “relevant to 

any party’s claim or defense” or “proportional to the needs of the case.” Fed. R. Civ. P. 26(b)(1). 

In its Motion for a Protective Order, Integrity argued that, based on the perfunctory allegations in 

the First Amended Complaint with respect to the two named plaintiffs who had any connection to 

Integrity, discovery should be limited to those two plaintiffs’ specific claims – a position supported 

by the plain language of Rule 26 and the Oregon Securities Law. (Integrity’s Mot. for Prot. Order 

at 3, 7.) 

Although the Court incorporates the proportionality analysis from the November 2016 

Opinion and Order,4 that analysis is inapposite in that the Court, when deciding the Accounting 

 4 In discussing proportionality, Magistrate Judge Acosta states in the February 2017 Opinion and 

Order:

The proportionality standard derived from the 2015 amendment to 

the Federal Rules of Civil Procedure 26(b)(l) and described in the 

court’s November 2016 Opinion and Order, 2016 WL 6963039, 

at *5, applies to the discovery which is the subject of the Moving 

Defendants’ respective motions for protective order.

(Feb. 2017 Opinion and Order at 8.)

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 6 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 7 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

Firm Defendants’ motions, only focused on proportionality with respect to a complete stay of

discovery, and not as a limitation on the scope of discovery:

The 2015 amendment to the Federal Rules of Civil Procedure 

26(b)(l) requiring that discovery now must be “proportionate to the 

needs of the case,” necessarily affects the determination whether a 

discovery stay should be granted pending determination of a 

dispositive motion * * *. Therefore, with amended Rule 26(b)(l) 

now in place, the court must consider proportionality when 

determining whether a stay of discovery is appropriate pending 

resolution of a potentially dispositive motion.

(Nov. 2016 Opinion and Order at 11-12, 14 (emphasis added).)

Even in its discussion of the Skellerup factors in the November 2016 Opinion and Order, 

the Court focuses only on whether a complete stay of discovery is warranted, and not on whether 

a limitation on the scope of discovery directed at irrelevant and burdensome document requests is 

appropriate. (Id. at 12-19.)

Nonetheless, in both the November 2016 and February 2017 Opinions and Orders, the 

Court ultimately held that only “limited, focused merits discovery should proceed.” (Nov. 2016 

Opinion and Order at 18-19; Feb. 2017 Opinion and Order at 8.) In the November 2016 Opinion 

and Order, the Court explicitly concluded that “Plaintiffs’ requests for production are 

disproportionate to the needs of the case at this stage.” (Nov. 2016 Opinion and Order at 19.) The 

Court also noted that:

In a complex case where pending motions to dismiss raise credible 

legal and factual issues, “the needs of the case” have not yet been 

finally established. Delaying discovery or limiting its scope until 

those issues are decided is appropriate and implements the 2015 

Amendment’s mandate for a renewed consideration of the time and 

money litigants must expend on discovery.

(Id. at 18.)

Despite the Court’s clearly manifested intent to limit and focus discovery in this matter, 

the plain language of Magistrate Judge Acosta’s specific discovery rulings with respect to Integrity 

has the opposite effect. Some of these rulings, if interpreted literally, expand the scope of 

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 7 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 8 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

discovery, rather than focusing and limiting the scope in accordance with “the needs of the case.” 

Judge Acosta held that Integrity was required to produce, within forty-five (45) days of entry of 

the Order, the following:

1. Integrity’s file for any named plaintiff who was an Integrity 

customer, including transaction-level documents.

2. All documents Integrity sent or received regarding the ACF 

Notes.

3. All documents Integrity sent or received regarding the AIOF-II 

Notes.

4. All promotional materials distributed by and presentations made 

by Integrity regarding any Aequitas company security.

5. All documents Integrity sent to and received from any Aequitas 

company regarding securities issued by or proposed to be issued 

by any Aequitas company.

6. All documents Ameritrade5 [sic] sent to and received from the 

Securities and Exchange Commission, the Consumer Financial 

Protection Bureau, the Department of Justice, and any state and 

federal regulatory and law enforcement agency relating to any 

inquiry or investigation of any Aequitas company.

7. The names, job titles, and designated primary office location of 

the employees who provided services to any named plaintiff 

who was an Integrity customer and bought any Aequitas 

security. For any employee no longer employed by Integrity, 

also provide the title of the last job held and the designated 

primary office location at the time employee separated from the

company.

(Feb. 2017 Opinion and Order at 11-12 (emphasis added).)

Integrity specifically objects to Rulings 2, 3 and 5, which are italicized in the above list, as 

unclear and expanding the scope of discovery far beyond the parameters established by Rule 26. 

Ruling No. 2 – “[a]ll documents Integrity sent or received regarding the ACF Notes” – is unclear 

in that the ruling does not specify from whom the documents in question were received or to whom 

the documents were sent. If the ruling was intended to include all documents sent, for example,

to Integrity’s clients regarding the ACF Notes, then potentially thousands of client account 

 5 Integrity and Plaintiffs have agreed that the reference in Ruling 6 is intended to be to Integrity 

and not to TD Ameritrade.

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 8 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 9 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

statements and related emails, which are irrelevant to the claims at issue in the instant litigation, 

would be included in the mandated production, making such production extremely burdensome 

and expensive. The same objection applies to Ruling No. 3, regarding the AIOF-II Notes. 

Furthermore, with respect to Ruling No. 2, neither of the named plaintiffs claims to have purchased 

an ACF Note through Integrity, making the costly and time-consuming production of “all 

documents” related to the ACF Notes even more irrelevant to any party’s claim or defense and 

disproportionate to the needs of the case. Fed. R. Civ. P. 26(b)(1). Integrity, however, has no 

objection to producing a form of subscription agreement and any promotional materials related to 

the ACF or AIOF-II Notes to Plaintiffs.

Integrity also objects to Ruling No. 5 – “[a]ll documents Integrity sent to and received from 

any Aequitas company regarding securities issued by or proposed to be issued by any Aequitas 

company.” If the Court’s ruling was intended to include, for example, emails, then thousands of 

potential documents could be implicated, the vast majority of which would be irrelevant to the 

scope of the instant litigation.

Integrity has no objections to the remainder of the Court’s rulings.

IV. ARGUMENT

A. Standard of Review.

When reviewing a magistrate judge’s order on a non-dispositive matter, a district court 

judge “shall modify or set aside any portion of the magistrate judge’s order found to be clearly 

erroneous or contrary to law.” Fed. R. Civ. P. 72(a); see also 28 U.S.C. § 636(b)(1)(A) (“A judge 

of the court may reconsider any pretrial matter * * * where it has been shown that the magistrate

judge’s order is clearly erroneous or contrary to law.”). “A finding is ‘clearly erroneous’ when 

although there is evidence to support it, the reviewing court on the entire evidence is left with the 

definite and firm conviction that a mistake has been committed.” United States v. U.S. Gypsum 

Co., 333 U.S. 364, 395 (1948); see also In re The Village at Lakeridge, LLC, 814 F.3d 993, 1002 

(9th Cir. 2016). Likewise, “under the ‘contrary to law’ standard of review, a district court may 

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 9 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 10 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

reverse a finding only if it finds that the magistrate fail[ed] to apply or misapplie[d] relevant 

statutes, case law or rules of procedure.” Garcia v. Benjamin Grp. Enter. Inc., 800 F. Supp. 2d 

399, 403 (E.D.N.Y. 2011) (citation and quotation marks omitted).

B. The Magistrate Judge Erred, as a Matter of Law, In Ordering the Burdensome 

Production of Documents Irrelevant to the Scope of and Disproportionate to the 

Needs of the Instant Litigation.

For the reasons set forth above, Integrity objects to Rulings 2, 3 and 5, ordering production 

of all documents Integrity sent or received regarding the ACF and AIOF-II Notes and related to 

any securities-related communication with any Aequitas entity. Although Magistrate Judge 

Acosta finds, in the Court’s February 2017 Opinion and Order, that discovery should be limited, 

the practical effect of Judge Acosta’s rulings, if interpreted literally, is to expand the scope of 

discovery beyond even Plaintiffs’ Document Requests. If ESI and emails are included, as 

Plaintiffs will undoubtedly claim, then responding to Plaintiffs’ RFPs will be extremely costly, 

time-consuming and burdensome. ESI is premature at this stage of the litigation – a fact that even 

Plaintiffs conceded in the Joint Report to the Court. (Joint Report at 7.) The expansive document 

production contemplated by a literal reading of Judge Acosta’s rulings is disproportionate to the 

needs of this case.

Integrity has no objections to the remainder of the Court’s rulings, assuming that ESI and 

emails are not contemplated by the rulings. In addition, Integrity is also willing to produce a form 

of subscription agreement and any promotional materials related to the ACF or AIOF-II Notes, as 

well as all agreements that Integrity executed with registered investment advisers related to 

“Aequitas securities” – a practical compromise that is also proportional to the needs of the case.

V. CONCLUSION

For the foregoing reasons, Integrity respectfully requests that Magistrate Judge Acosta’s 

February 2017 Opinion and Order be vacated, and that the Court grant Integrity’s Motion for a 

Protective Order. Alternatively, Integrity Bank respectfully requests that the Court recommit this 

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 10 of 11
711269.0001/6889463.1

LANE POWELL PC

601 SW SECOND AVENUE, SUITE 2100

PORTLAND, OREGON 97204-3158

503.778.2100 FAX: 503.778.2200

PAGE 11 - DEFENDANT INTEGRITY BANK & TRUST’S OBJECTION TO OPINION AND 

ORDER

dispute to Magistrate Judge Acosta for clarification regarding the scope of the Court’s rulings in 

the February 2017 Opinion and Order.

DATED: March 7, 2017

LANE POWELL PC

By /s/ Milo Petranovich

Milo Petranovich, OSB No. 813376

Peter D. Hawkes, OSB No. 071986

SreeVamshi C. Reddy, OSB No. 140560

Telephone: 503.778.2100

Attorneys for Defendant Integrity Bank & Trust

Case 3:16-cv-00580-AC Document 218 Filed 03/07/17 Page 11 of 11