STIPULATION AND CONSENT ORDER CONCERNING CONFIDENTIAL DOCUMENTS AND INFORMATION

DAVID E. RICE, Bankruptcy Judge.

Plaintiff, Daisy Couloote Phillip ("Phillip") and Defendant David Reecher ("Reecher") (collectively "Parties"), by their undersigned counsel, hereby enter into this Stipulation and Consent Order Concerning Confidential Documents and Information ("Stipulation").

WHEREAS, documents, materials and information will be produced in the above-captioned case by Reecher in discovery as per Honorable Judge Rice' Order dated January 15, 2013 and entered on January 16, 2013 ("Order"); and

THEREFORE, IT IS HEREBY AGREED AND STIPULATED BY THE UNDERSIGNED THAT:

1. This Stipulation shall apply and be applicable to and shall govern all documents, materials and information produced by Reecher which prior to the date of this order were marked as Confidential, and documents produced after the date of this order pursuant to the Court's Order which are labeled as "CONFIDENTIAL"

2. None of the documents, information contained therein, nor copies or transmittals thereof labeled or designated as "CONFIDENTIAL," shall be disclosed, divulged, revealed, described, transmitted or otherwise communicated by any Party or by the attorneys of any Party to any other person except: (a) to a member or employee or agent of the law firms of counsel of record in this cause, to the extent such person is performing work in connection with this case and solely for use in this case; (b) to a Party to the action, including the agents and employees of a Party, to the extent such person is performing work in connection with this case and only for purposes related to this case; (c) to experts and their staff retained by counsel of record to assist in the preparation of the action for trial, including consulting experts and solely for use in connection with this case; (d) to a witness or potential witness for the sole purpose of eliciting, preparing or developing written or oral testimony by such witness in this case; (e) to the Court; (f) to the jury; and (g) to Court reporters.

3. The attorneys of record shall provide a copy of this Stipulation to each person designated in paragraph 2 (a)-(d) above who is given access to documents or information covered by this Stipulation, and shall advise each such person that he/she is bound by and required to comply with the terms of this Stipulation and each such person shall sign an acknowledgement of this obligation on the form attached hereto. Each of the Parties further agrees to maintain a list of all persons to whom access is given to documents and information covered by this Stipulation.

4. Each person to whom disclosure of documents or information covered by this Stipulation is made in accordance with this Stipulation is hereby prohibited from disclosing or divulging such documents or information without proper authorization; from exploiting in any way such material for his/her/its benefit, or from using such material for any purpose or in any manner not connected with the prosecution or defense of this case; except if the disclosing person was a party to such document or the transaction to which the document is related.

5. Within thirty (30) days of the final disposition of this action, upon the written request by a Party, all documents and materials produced pursuant to this Stipulation, including excerpts or copies, shall be returned to the attorneys of record for the Parties who produced them, or counsel for the party who received the documents and materials shall destroy and promptly provide certification to opposing counsel of the destruction of same.

6. This Stipulation shall remain in full force and effect until the final disposition of this cause, until modified, superseded or terminated by consent of the Parties or their counsel in writing, or by Order of the Court, and does not prejudice the right of any Party to this Stipulation to seek modification by Court Order or agreement.

7. It is understood and agreed that the execution of this Stipulation shall in no way constitute a waiver of the right of any Party to the action to raise or assert any objections to any discovery request made, including but not limited to defenses or objections as to relevancy, admissibility or authenticity of any documents, materials or information, and the Parties each agree that if an objection is made by one or more of the Parties, that no Party shall use this Stipulation or make reference to the existence of this Stipulation in arguing for or against any such objection.

8. This Stipulation does not apply to documents or information any one or more of the Parties have received from other sources, including but not limited to third-parties.

9. In the event any of the Parties to this Stipulation shall file any Confidential documents or make reference to any Confidential information with the Court by way of pleadings, motions, briefs, or any other papers containing or attaching such documents or information, the document(s) containing such Confidential documents and information shall be filed in a sealed envelope which will state: (a) the style and cause number of this case; and (b) the following words:

CONFIDENTIAL

THIS ENVELOPE CONTAINS DOCUMENTS AND INFORMATION THAT ARE SUBJECT TO STIPULATION FILED WITH THE COURT IN THIS ACTION GOVERNING THE USE OF CONFIDENTIAL MATTER

10. The provisions of paragraph 9 do not apply to exhibits offered at the time of trial, or at pretrial pursuant to court order provided however, the other party shall be entitled to seek such protective orders concerning the confidential documents and information to be introduced at trial as it deems reasonable and/or necessary to protect confidential documents and information from public disclosure.

11. This Stipulation shall be without prejudice to the right of the parties (i) to bring before the Court at any time the question of whether any particular document or information is confidential or whether its use should be restricted or (ii) to present a motion to the Court under the applicable rules of procedure for a separate protective order as to any particular document or information, including restrictions differing from those as specified herein. Each of the Parties agree that if such occurs, that no Party shall use this Stipulation or make reference to the existence of this Stipulation in connection therewith. At all times the burden of establishing confidentiality remains with the designating party.

12. This Stipulation shall not be deemed to prejudice the parties in any way in any future application for modification of this Stipulation.

SO ORDERED.

AGREEMENT TO COMPLY WITH STIPULATION CONCERNING CONFIDENTIAL DOCUMENTS AND INFORMATION

I hereby acknowledge that I have been provided with a copy of and have read the Stipulation Concerning Confidential Documents and Information ("Stipulation") in this case and that as a condition of being permitted to have access to documents and information which one or more of the Parties to this case have designated as Confidential, that I agree to be bound by and to fully comply with each of the provisions and terms of this Stipulation.