UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF ILLINOIS

EASTERN DIVISION

PRINZO & ASSOCIATES, LLC, on behalf of 

itself and all others similarly situated,

Plaintiff, 

v.

BMO HARRIS BANK N.A., BMO 

FINANCIAL CORP., a Delaware corporation; 

and DOES 1 through 100, inclusive,

Defendants.

Civil No. 20-cv-3256

Hon. Gary S. Feinerman

AGREED MOTION FOR ENTRY OF (i) JOINT PROPOSED PROTOCOL FOR THE 

PRODUCTION OF ELECTRONICALLY STORED INFORMATION AND (ii) 

CONFIDENTIALITY ORDER

The parties, by their undersigned counsel, hereby move this Court for the entry of their 

Joint Proposed Protocol for the Production of Electronically Stored Information and their Agreed 

Confidentiality Order, and in support of this motion states as follows: 

1. The parties anticipate production of electronically stored information (“ESI”) and the 

exchange of discovery involving sensitive information. 

2. The parties have met and conferred to prepare an acceptable form of ESI production 

protocol (“ESI Protocol,” attached hereto as Exhibit 1) and an Agreed Confidentiality Order 

(“Confidentiality Order,” attached hereto as Exhibit 2) to be used in connection with the case. 

3. Pursuant to the Court’s rules, Microsoft Word versions of the ESI Protocol and 

Confidentiality Order are simultaneously being submitted to the Court’s proposed order e-mail 

box. 

Case: 1:20-cv-03256 Document #: 25 Filed: 08/14/20 Page 1 of 3 PageID #:74
4. The parties believe that entry of the ESI Protocol and Confidentiality Order will facilitate 

document production and discovery in this action. 

Wherefore, the parties respectfully move the Court for the entry of the ESI Protocol and 

Confidentiality Order attached as Exhibits 1 & 2.

Dated: August 14, 2020 Respectfully Submitted, 

/s/ Leigh M. Perica________ 

Derek Y. Brandt (#6228895)

Leigh M. Perica (#6316756)

MCCUNE WRIGHT AREVALO, LLP

231 North Main Street, Suite 20

Edwardsville, Illinois 62025

Tel: (618) 307-611

Fax: (618) 307-6161

DYB@mccunewright.com

LMP@mccunewright.com

Richard D. McCune (pro hac vice)

Michele M. Vercoski (pro hac vice)

MCCUNE WRIGHT AREVALO, LLP

3281 East Guasti Road, Suite 100

Ontario, California 91761

Tel: (909) 557-1250

RDM@mccunewright.com

MMV@mccunewright.com

Counsel for Plaintiff Prinzo & 

Associates, LLC

/s/ Jeffrey E. Jamison (with consent)

Jeffrey E. Jamison

BMO HARRIS BANK N.A.

111 West Monroe

19th Floor

Chicago, IL 60603

Tel: (312) 461-4694

jeffrey.jamison@bmo.com

Julie Rodriguez Aldort

BMO HARRIS BANK N.A.

111 W. Monroe Street

Fl. 11E

Chicago, IL 60603

Tel: (312) 461-7905

julie.aldort@bmo.com

Counsel for Defendants BMO Harris Bank N.A. 

and BMO Financial Corp.

Case: 1:20-cv-03256 Document #: 25 Filed: 08/14/20 Page 2 of 3 PageID #:75
CERTIFICATE OF SERVICE

The undersigned hereby certifies that the accompanying Agreed Motion for Entry of (i) 

Joint Proposed Protocol for the Production of Electronically Stored Information and (ii) 

Confidentiality Order was filed on this date electronically through the Court’s CM/ECF system, 

which will send an electronic notice to counsel of record for all parties. 

/s/ Leigh M. Perica________ 

Case: 1:20-cv-03256 Document #: 25 Filed: 08/14/20 Page 3 of 3 PageID #:76