Case 1:15-cv-00293-LTS-RWL Document 172 Filed 05/05/17 Page 1 of 3

UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK

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MORTGAGE RESOLUTION SERVICING, LLC,

!ST FIDELITY LOAN SERVICING, LLC, and No. 15-CV-00293 (LTS) (JCF)

S&A CAPITAL PARTNERS, INC.,

Plaintiffs, AFFIDAVIT OF NON-PARTY

- v. - WITNESS BRYAN BLY

JPMORGAN CHASE BANK, N.A., CHASE HOME

FINANCE LLC, and JPMORGAN CHASE & CO.

Defendants.

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STATE OF FLORIDA )

) ss.:

COUNTY OF Pl/,,j43 )

BRYAN BLY, being duly sworn, deposes and says:

I. My name is Bryan Bly and I am above the age of 1 8 years and competent to testify. I

have personal knowledge of the matters stated herein. I submit this affidavit in opposition to the

motion filed on April 14, 2017 by Plaintiffs S&A Capital Partners, Inc. ("S&A"), Mortgage

Resolution Services, LLC ("MRS"), and !st Fidelity Loan Servicing ("!st Fidelity") (collectively,

"Plaintiffs") for an order setting aside the designation of Mr. Bly and Ms. Lance's depositions as

"Confidential" or "Attorneys Eyes Only." I am not a party to this litigation.

2. I have been employed by Nationwide Title Clearing, Inc. ("NTC") for approximately

fourteen years. In connection with my work duties, my deposition has been taken on several

occasions. My current title is Title Policy Researcher.

3. I am currently 58 years old and am partially disabled.

 Case 1:15-cv-00293-LTS-RWL Document 172 Filed 05/05/17 Page 2 of 3

4. In or around 2010, transcripts and videos ofmy depositions, and those ofmy

co-workers, were posted on the internet and publically shared.

5. As a result, I was subjected to harassment, embarrassment, and threats of physical

harm. Among other things, I was subject to harassment by commenters on the internet, including at

least one individual who suggested I deserved to die. I also received numerous mysterious calls from

individuals who refused to identify themselves. A particularly frightening incident involved my

elderly father walking along the street heading to my home when a car began to follow him. The car

followed him until he reached my front door, at which point an individual exited the car and began

walking toward my father, asking him questions relating to me. My father entered my home and

slammed the door. As a result of this incident, I felt it was necessary to move to a new residence

and did so within a matter of weeks.

6. Other NTC employees have experienced similar harassment, annoyance, and threats

of physical harm as a result of the publication of their depositions.

7. Under the circumstances, and fearing for our personal safety and the safety of our

families, I and other NTC employees have been forced to seek protective orders in Florida to limit the

disclosure which had occurred and to prevent future disclosure.

8. Before my deposition in this case on March 2 1 , 2017, I believed that it had been

agreed that the protective order in place in the case would apply and my transcript and video would be

designated and would remain as confidential.

9. Had I understood that Plaintiffs would contest the confidentiality designation, I would

have sought a protective order prior to appearing for the deposition.

2
 Case 1:15-cv-00293-LTS-RWL Document 172 Filed 05/05/17 Page 3 of 3

I 0. Based upon past experiences and occurrences, I have a reasonable and good faith

belief that the removal of the confidential designation placed upon my deposition transcript would

subject me to harassment, embarrassment, and threats of bodily harm.

FURTHER AFFIANT SA YETH NAUGHT .

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