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(15-00293 211-7) Ex 7 Affidavit of Non-Party Witness Bryan Bly Filed 5 5 2017
(15-00293 211-7) Ex 7 Affidavit of Non-Party Witness Bryan Bly Filed 5 5 2017
EXHIBIT 7
Case
Case1:15-cv-00293-LTS-RWL
1:15-cv-00293-LTS-JCF Document
Document211-7 Filed05/05/17
172 Filed 07/20/17 Page
Page1 2ofof3 4
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!ST FIDELITY LOAN SERVICING, LLC, and No. 15-CV-00293 (LTS) (JCF)
Defendants.
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STATE OF FLORIDA )
) ss.:
COUNTY OF Pl/,,j43 )
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
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
4. In or around 2010, transcripts and videos ofmy depositions, and those ofmy
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
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
6. Other NTC employees have experienced similar harassment, annoyance, and threats
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
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
9. Had I understood that Plaintiffs would contest the confidentiality designation, I would
2
Case
Case1:15-cv-00293-LTS-RWL
1:15-cv-00293-LTS-JCF Document
Document211-7 Filed05/05/17
172 Filed 07/20/17 Page
Page3 4ofof3 4
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
Sworn to under oath and signed before me thisa-v- day of___..........._ _-._, Bryan Bly,
who is personally known to me or who has produced -w:;...,,;..u..<...,;;....a........u.u...;:="-"-"'- cation and
who took an oath.
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