Wallace v. Nationstar Mortgage LLC ( 2020 )

1 AKERMAN LLP JUSTIN D. BALSER (SBN 213478) 2 Email: justin.balser@akerman.com NATALIE L. WINSLOW (SBN 281704) 3 Email: natalie.winslow@akerman.com 601 West Fifth Street, Suite 300 4 Los Angeles, CA 90071 Telephone: (213) 688-9500 5 Facsimile: (213) 627-6342 6 Attorneys for Defendant/Counterclaimants NATIONSTAR MORTGAGE LLC dba MR. COOPER f/k/a Centex Home Equity Co. 7 LLC and BANK OF NEW YORK MELLON f/k/a THE BANK OF NEW YORK as successor in interest to JPMorgan Chase Bank, N.A., as 8 Trustee for Centex Home Equity Loan Trust 2005-A 9 UNITED STATES DISTRICT COURT 10 FOR THE EASTERN DISTRICT OF CALIFORNIA 11 12 DENISE WALLACE, No. 2:18-cv-02768-JAM-DB 13 Plaintiff, STIPULATED PROTECTIVE ORDER AND ORDER 14 v. 15 NATIONSTAR MORTGAGE, LLC, Individually and dba MR. COOPER, 16 CENTREX HOME EQUITY, LLC., THE BANK OF NEW YORK 17 MELLON, THE MORTGAGE LAW FIRM and DOES 1-100, inclusive, 18 Defendants. 19 Defendants Nationstar Mortgage LLC dba Mr. Cooper f/k/a/ Centex Home 20 Equity Co. LLC (Nationstar) and Bank of New York Mellon f/k/a/ the Bank of New 21 York as successor in interest to JPMorgan Chase Bank, N.A., as Trustee for the Centex 22 Home Equity Loan Trust 2006-A (BoNYM, and together with Nationstar, defendants) 23 and plaintiff Denise Wallace by and through their attorneys of record, stipulate to the 24 following Protective Order: 25 To expedite the flow of discovery, facilitate the prompt resolution of disputes 26 over confidentiality, adequately protect material claimed to be confidential, and ensure 27 1 protection is afforded only to material so designated, it is, pursuant to the Court's 2 authority under Federal Rules of Civil Procedure 26(c), ORDERED this Protective 3 Order shall govern the disclosure, handling and disposition of documents in this 4 litigation as follows: 5 1. Application. 6 1.1 This Protective Order shall govern any document, information or other 7 material that is designated as containing "Confidential Information" as defined herein, 8 and is produced in connection with this litigation by any person or entity (the "producing 9 party"), whether in response to a discovery request, subpoena or otherwise, to any other 10 person or entity (the "receiving party") regardless of whether the person or entity 11 producing or receiving such information is a party to this litigation. 12 1.2 The party who asserts that particular information should be treated as 13 Confidential Information under this Protective Order has the burden of proof to 14 establish that the information or document is entitled to such protection. 15 2. Definitions. 16 2.1 Confidential Information. "Confidential Information" shall mean and 17 include, without limitation, any non-public information that concerns or relates to the 18 following areas: personal information protected by a right to privacy, individual health 19 information, including but not limited to medical records, individual treatment records, 20 and individual mental health treatment information, confidential proprietary 21 information, trade secrets, practices and procedures, personal financial information, 22 commercial, financial, pricing, budgeting, and/or accounting information, information 23 about existing and potential customers, marketing studies, performance projections, 24 business strategies, decisions and/or negotiations, personnel compensation, evaluations 25 and other employment information, and confidential proprietary information about 26 affiliates, parents, subsidiaries and third-parties with whom the parties to this action 27 have or have had business relationships. 1 2.2 Documents. As used herein, the term "documents" includes all writings, 2 records, files, drawings, graphs, charts, photographs, e-mails, video tapes, audio tapes, 3 compact discs, electronic messages, other data compilations from which information 4 can be obtained and other tangible things subject to production under the Federal Rules 5 of Civil Procedure. 6 3. Initial Designation. 7 3.1 Good Faith Claims. Claims of confidentiality will be made only with 8 respect to documents, other tangible things and information that the asserting party has 9 a good faith belief are within the definition set forth in subparagraph 2.1 of this 10 Protective Order. Objections to such claims made pursuant to paragraph 5, below, shall 11 also be made only in good faith. 12 3.2 Produced Documents. A party producing documents that it believes 13 constitute or contain Confidential Information shall state that the material is being 14 produced under this Protective Order by describing the documents or materials to be 15 treated as confidential in writing, by page or bates number wherever possible and/or 16 shall produce copies bearing a label that contains or includes language substantially 17 identical to the following: 18 CONFIDENTIAL 19 This label shall be affixed in a manner that does not obliterate or obscure the 20 contents of the copies. If any person or party makes copies of documents designated as 21 containing Confidential Information, the copying person or party shall mark each such 22 copy as containing Confidential Information in the same form as the Confidentiality 23 notice on the original document. 24 A party producing documents that are stored on electronic, magnetic, optical or 25 other non-paper media, such as compact discs, DVD's, video tapes and audio tapes 26 (collectively, "data storage devices") shall designate the data storage device as 27 containing Confidential Information, by affixing a label or stamp to the data storage 1 device in the manner described above at the time copies of such data storage devices 2 are produced. If the receiving party or other persons or entities to whom disclosure is 3 authorized pursuant to subparagraph 7.1 make a copy of any data storage device 4 designated by the producing party as containing Confidential Information, the receiving 5 party or other authorized person shall mark each such copy as containing Confidential 6 Information in the same form as the confidentiality notice on the original data storage 7 device produced. If the receiving party or other authorized person prints out or 8 otherwise makes copies of the documents or information stored on such data storage 9 device, the receiving party or other authorized person shall mark each page so copied 10 with the label or stamp specified in subparagraph 3.2. 11 3.3 Interrogatory Answers. If a party answering an interrogatory or other 12 discovery demand believes that its answer contains Confidential Information, it shall 13 state so in the interrogatory response, and that portion of the response will be entitled 14 to the protections of this order. 15 3.4 Inspection of Documents. In the event a party elects to produce files and 16 records for inspection and the requesting party elects to inspect them, no designation of 17 Confidential Information needs to be made in advance of the inspection. For purposes 18 of such inspection, all material produced shall be considered as Confidential 19 Information. If the inspecting party selects specified documents to be copied, the 20 producing party shall designate Confidential Information in accordance with 21 subparagraph 3.2 at the time the copies are produced. 22 3.5 Deposition Transcripts. The party asserting confidentiality shall state on 23 the record the portions it deems confidential. The failure to designate testimony on the 24 record as confidential shall be a waiver unless the designating party notifies all other 25 parties and files a motion to designate the testimony as confidential within 5 days of the 26 notification. 27 3.6 Inadvertent Failure to Designate. Inadvertent failure to identify documents 1 or things as "Confidential" pursuant to this Protective Order shall not constitute a waiver 2 of any otherwise valid claim for protection, provided that the provisions of this 3 paragraph are satisfied. If the designating party discovers that information should have 4 but was not designated "Confidential" or of the designating party receives notice that 5 would enable the designated party to learn that it has disclosed such information, the 6 designating party must immediately notify all other parties. In such event, within thirty 7 (30) days of notifying all other parties, the designating parties must also provide copies 8 of the "Confidential" information designated in accordance with this Protective Order. 9 After receipt of such re-designated information, the "Confidential" information shall be 10 treated as required by this Protective Order, and the receiving party(ies) shall promptly, 11 and in no event more than fourteen (14) calendar days from the receipt of the re- 12 designated information, return to the designated party all previously produced copies of 13 the same unlegended documents or things. The designating party and the parties may 14 agree to alternative means. The receiving party(ies) shall receive no liability, under this 15 Protective Order or otherwise, for any disclosure of information contained in 16 unlegended documents or things occurring before the receiving party was placed on 17 notice of the designating party's claims of confidentiality. 18 4. Designations by Another Party. 19 4.1 Notification of Designation. If a party other than the producing party 20 believes that a producing party has produced a document that contains or constitutes 21 Confidential Information of the non-producing party, the non-producing party may 22 designate the document as Confidential Information by so notifying all parties in writing 23 within fourteen (14) days of service of the document. 24 4.2 Return of Documents; Non-disclosure. Whenever a party other than the 25 producing party designates a document produced by a producing party as Confidential 26 Information in accordance with subparagraph 4.1, each party receiving the document 27 shall either add the Confidential Information designation in accordance with 1 subparagraph 3.2 or substitute a copy of the document bearing such designation for each 2 copy of the document produced by the producing party. Each party shall destroy all 3 undesignated copies of the document or return those copies to the producing party, at 4 the direction of the producing party. No party shall disclose a produced document to 5 any person, other than the persons authorized to receive Confidential Information under 6 subparagraph 7.1, until after the expiration of the fourteen (14) day designation period 7 specified in subparagraph 4.1. If during the fourteen (14) day designation period a party 8 discloses a produced document to a person authorized to receive Confidential 9 Information under subparagraph 7.1, and that document is subsequently designated as 10 Confidential Information in accordance with subparagraph 4.1, the disclosing party 11 shall cause all copies of the document to be destroyed or returned to the producing party, 12 at the direction of the producing party. The party may thereafter disclose a copy of the 13 document that has been marked as Confidential Information by the designating party, 14 in accordance with subparagraphs 3.2 and 7.1. 15 5. Objections to Designations. Any party objecting to a designation of 16 Confidential Information, including objections to portions of designations of multi-page 17 documents, shall notify the designating party and all other parties of the objection in 18 writing up to and through trial of the matter. This notice must specifically identify each 19 document that the objecting party in good faith believes should not be designated as 20 Confidential Information and provide a brief statement of the grounds for such belief. 21 In accordance with the Federal Rules of Civil Procedure governing discovery disputes, 22 the objecting and the designating parties thereafter shall confer within ten (10) days 23 after the date of such objection in an attempt to resolve their differences. If the parties 24 are unable to resolve their differences, the objecting party shall have twenty one (21) 25 days after the conference concludes to file with the Court a motion to remove the 26 Confidential Information. If an objection is served within forty-two (42) days of trial, 27 the objecting party must file its motion to remove the Confidential Information 1 designation within half of the remaining time before trial, and the meet-and-confer 2 period shall be shortened accordingly. Where a party authored, created, owns, or 3 controls a document, information or other material that another party designates as 4 Confidential Information, the party that authored, created, owns, or controls the 5 Confidential Information may so inform the objecting party and thereafter shall also be 6 considered a designating party for purposes of this paragraph. 7 All documents, information and other materials initially designated as 8 Confidential Information shall be treated as such in accordance with this Protective 9 Order unless and until the Court rules otherwise, except for deposition transcripts and 10 exhibits initially considered as containing Confidential Information under subparagraph 11 3.5, which will lose their confidential status after twenty-one (21) days unless so 12 designated as Confidential Information. If the Court rules that a designation should not 13 be maintained as to a particular document, the producing party shall, upon written 14 request by a party, provide that party a copy of that document without the designation 15 described in subparagraph 3.2. 16 If an objecting party elects not to make such a motion with respect to documents 17 within twenty one (21) days after the conference, information or other materials to 18 which an objection has been made, the objection shall be deemed withdrawn. The 19 designating party shall have twenty one (21) days to respond to the objecting party's 20 motion. If no response is filed by the designating party within twenty one (21) days, 21 the designating party shall be deemed to have consented to the objecting party's motion. 22 6. Custody. All Confidential Information and any and all copies, extracts and 23 summaries thereof, including memoranda relating thereto, shall be retained by the 24 receiving party in the custody of counsel of record, or by persons to whom disclosure 25 is authorized under subparagraph 7.1. 26 7. Handling Prior to Trial. 27 7.1 Authorized Disclosures. Confidential Information shall be disclosed by the 1 receiving party only to the following persons: 2 a. Counsel for the parties in this litigation, including their associates, clerks, 3 paralegals, and secretarial personnel; 4 b. Qualified persons taking testimony in this litigation involving such 5 Confidential Information, and necessary stenographic, videotape and clerical personnel; 6 c. Experts and their staff who are retained by counsel as expert witnesses for 7 a party in this litigation; 8 d. Experts and their staff who are consulted by counsel for a party in this 9 litigation; 10 e. Parties to this litigation, limited to the named party and, if that party is a 11 corporate entity, a limited number of employees of the corporate entity and its insurers; 12 f. Designated in-house counsel and a limited number of assistants, 13 administrative or otherwise; 14 g. Outside vendors employed by counsel for copying, scanning and general 15 handling of documents; 16 h. Any person of whom testimony is taken regarding the Confidential 17 Information, except that such person may only be shown Confidential Information 18 during his/her testimony, and may not retain a copy of such Confidential Information; 19 and 20 i. This Court and this Court's staff, subject to the Court's processes for filing 21 materials under seal. 22 Such disclosures are authorized only to the extent necessary to investigate, 23 prosecute, or defend the litigation. 24 Confidential Information may not be disclosed to persons under subparagraphs 25 (c) or (d) until the receiving party has obtained a written acknowledgment from the 26 person receiving Confidential Information, in the form of the Declaration attached 27 hereto as Exhibit A, that he or she has received a copy of this Protective Order and has 1 agreed to be bound by it. A party who discloses Confidential Information in accordance 2 with subparagraph 7.1 shall retain the written acknowledgment from each person 3 receiving Confidential Information, shall maintain a list of all persons to whom a 4 receiving party has disclosed Confidential Information and identify what documents 5 have been disclosed, and shall furnish the written acknowledgments and disclosure list 6 to opposing counsel as follows: (i) for a person under subparagraph (c), within thirty 7 (30) days after the person signs the Declaration; and (ii) for a person under subparagraph 8 (d), within thirty (30) days after the matter is finally concluded. Disclosure of 9 Confidential Information to this Court, including judicial staff, shall be made in 10 accordance with subparagraph 7.4 of this Protective Order. 11 7.2 Unauthorized Disclosures. All persons receiving Confidential Information 12 under the terms of this Protective Order are under the jurisdiction of the state courts and 13 U.S. federal courts located in California for all matters arising from the improper 14 disclosure or use of such information. If Confidential Information is disclosed to any 15 person other than in the manner authorized by this Protective Order, the party or person 16 responsible for the disclosure, and any other party or person who is subject to this 17 Protective Order and learns of such disclosure, shall immediately bring such disclosure 18 to the attention of the designating party. Without prejudice to other rights and remedies 19 of the designating party, the responsible party or person shall make every effort to obtain 20 and return the Confidential Information and to prevent further disclosure on its own part 21 or on the part of the person who was the unauthorized recipient of such information. 22 7.3 Court Filings. In the event any Confidential Information must be filed with 23 the Court prior to trial, the proposed filing shall be accompanied by a motion to file the 24 Confidential Information under seal and a proposed order, and the application and 25 proposed order shall be directed to the judge to whom the Confidential Information is 26 directed. This provision is applicable to briefs, memoranda, and other filings which 27 quote, summarize, or describe Confidential Information. 1 8. Care in Storage. Any person in possession of Confidential Information 2 produced by another party shall exercise reasonable and appropriate care with regard to 3 the storage, custody, copying, and use of such information to ensure that the confidential 4 and sensitive nature of same is maintained. 5 9. Handling During Trial. Confidential Information that is subject to this 6 Order may be marked and used as trial exhibits by either party, subject to terms and 7 conditions as imposed by the Court upon application by any party. 8 10. No Implied Waivers. This Protective Order shall not be interpreted as a 9 waiver of the right to object, under applicable law, to the furnishing of information in 10 response to discovery requests or to object to a requested inspection of documents or 11 facilities. Parties producing Confidential Information in this litigation are doing so only 12 pursuant to the terms of this Protective Order. The taking of any action in accordance 13 with the provisions of this Protective Order shall not be interpreted as a waiver of any 14 claim or position or defense in this action, or any other actions. 15 11. No Admission. The designation of any item as Confidential Information 16 shall not be construed as an admission that such material, or any testimony concerning 17 such material, would be admissible in evidence in this litigation or in any other 18 proceeding. 19 12. Inadvertent Disclosure. Nothing in this Protective Order abridges 20 applicable law concerning inadvertent disclosure of a document that the Disclosing 21 Party believes contains attorney-client communications, attorney work product, or 22 otherwise privileged information. If a party inadvertently discloses documents or 23 information subject to a claim of privilege or work product protection, such disclosure 24 will not waive otherwise applicable claims of privilege or work product protection 25 under applicable law. Upon discovery by the Receiving Party, or receipt of written 26 notice from the Disclosing Party identifying privileged or protected Documents that 27 were inadvertently produced, the receiving party shall within seven (7) business days 1 either: (a) return or certify the destruction of all such documents, all copies, and any 2 work product or portions of any work product containing or reflecting the contents of 3 the subject materials; or (b) after attempting to resolve any dispute with opposing 4 counsel informally, file a motion to challenge the assertion of privilege and tender the 5 subject documents for in camera review with the motion. The moving party shall do 6 nothing to compromise the privilege claim until the Court rules on said motion and the 7 opportunity for appellate review is exhausted or the issue is otherwise resolved. 8 13. Parties' Own Documents. This Protective Order shall in no way restrict 9 the parties in their use of their own documents and information, and nothing in this 10 Protective Order shall preclude any party from voluntarily disclosing its own documents 11 or information to any party or nonparty. 12 14. Motion by Third Party to Compel Production of Confidential 13 Information. If any third party subpoenas Confidential Information from a party to this 14 action or moves to compel a party to this action to produce any such information, such 15 party shall immediately notify the parties who originally produced and/or designated 16 such information that a subpoena has been served or a motion has been made in order 17 to allow the parties who originally produced and/or designated such information the 18 opportunity to seek a protective order or oppose the motion or application. If, within 19 thirty (30) days after receiving notice of a subpoena seeking Confidential Information 20 from a receiving party, the party who originally produced and/or designated such 21 information fails to move for a protective order, the party subject to the subpoena may 22 produce said information. In addition, if a party is ordered to produce Confidential 23 Information covered by this Protective Order, then notice and, if available, a copy of 24 the order compelling disclosure shall immediately be given the parties who originally 25 produced and/or designated such information. Nothing in this Protective Order shall be 26 construed as requiring the party who is ordered to produce such Confidential 27 Information to challenge or appeal any order requiring the production of such 1 information or to subject himself/herself to any penalty for non-compliance with any 2 legal process or seek any relief from the Court. 3 15. No Effect on Other Rights. This Protective Order shall in no way 4 abrogate or diminish any pre-existing contractual, statutory, or other legal obligations 5 or rights of any party with respect to Confidential Information. 6 16. Modification. In the event any party hereto seeks a Court order to modify 7 the terms of this Protective Order, or seeks a protective order which incorporates the 8 terms and conditions of this Protective Order said party shall make such request by 9 written stipulation or noticed motion to all parties that must be served and filed in 10 accordance with local court rules. 11 17. Handling Upon Conclusion of Litigation. All parties, counsel, and 12 persons to whom disclosure was made agree to return all Confidential Information to 13 the designating party within thirty (30) days of the conclusion of litigation between the 14 parties, including final appellate action or the expiration of time to appeal or seek further 15 review. In addition, counsel shall certify in writing that all such Confidential 16 Information have been returned. Counsel for each party also shall contact each person 17 to whom that party has provided a copy of any Confidential Information and request the 18 documents be returned. In lieu of returning Confidential Information, the person or 19 party in possession of such information may elect to destroy it. If the person or party in 20 possession of Confidential Information elects to destroy it rather than return it, that 21 person or party must notify the designating party in writing of the destruction of the 22 information within ninety (90) days of the conclusion of litigation between the parties, 23 including final appellate action or the expiration of time to appeal or seek further review. 24 25 26 27 1 18. Survival of the Terms of this Protective Order. Even after the 2 termination of this litigation, the confidentiality obligations imposed by this Protective 3 Order shall remain in effect until a Designating Party otherwise in writing or a court 4 order otherwise directs. 5 6 Dated: July 13, 2020 AKERMAN LLP 7 By: /s/ Natalie L. Winslow 8 Justin D. Balser Natalie L. Winslow 9 Attorneys for Defendants NATIONSTAR MORTGAGE LLC dba MR. 10 COOPER f/k/a Centex Home Equity Co. LLC and BANK OF NEW YORK MELLON f/k/a 11 THE BANK OF NEW YORK as successor in interest to JPMorgan Chase Bank, N.A., as 12 Trustee for Centex Home Equity Loan Trust 2005-A 13 14 Dated: July 13, 2020 SPINELLI, DONALD & NOTT 15 16 By:/s/ Ross R. Nott 17 Ross R. Nott Daniel B. Phung 18 Attorneys for Plaintiff DENISE WALLACE 19 20 21 22 23 24 25 26 27 1 ORDER 2 Pursuant to the parties’ stipulation, IT IS SO ORDERED. 3 IT IS FURTHER ORDERED THAT: 4 1. Requests to seal documents shall be made by motion before the same judge 5 who will decide the matter related to that request to seal. 6 2. The designation of documents (including transcripts of testimony) as 7 confidential pursuant to this order does not automatically entitle the parties to file such 8 a document with the court under seal. Parties are advised that any request to seal 9 documents in this district is governed by Local Rule 141. In brief, Local Rule 141 10 provides that documents may only be sealed by a written order of the court after a 11 specific request to seal has been made. L.R. 141(a). However, a mere request to seal 12 is not enough under the local rules. In particular, Local Rule 141(b) requires that “[t]he 13 ‘Request to Seal Documents’ shall set forth the statutory or other authority for sealing, 14 the requested duration, the identity, by name or category, of persons to be permitted 15 access to the document, and all relevant information.” L.R. 141(b). 16 3. A request to seal material must normally meet the high threshold of showing 17 that “compelling reasons” support secrecy; however, where the material is, at most, 18 “tangentially related” to the merits of a case, the request to seal may be granted on a 19 showing of “good cause.” Ctr. for Auto Safety v. Chrysler Grp., LLC, 809 F.3d 1092, 20 1096-1102 (9th Cir. 2016); Kamakana v. City and County of Honolulu, 447 F.3d 1172, 21 1178-80 (9th Cir. 2006). 22 4. Nothing in this order shall limit the testimony of parties or non-parties, or the 23 use of certain documents, at any court hearing or trial – such determinations will only 24 be made by the court at the hearing or trial, or upon an appropriate motion. 25 5. With respect to motions regarding any disputes concerning this protective 26 order which the parties cannot informally resolve, the parties shall follow the procedures 27 1 outlined in Local Rule 251. Absent a showing of good cause, the court will not hear 2 discovery disputes on an ex parte basis or on shortened time. 3 6. The parties may not modify the terms of this Protective Order without the 4 court’s approval. If the parties agree to a potential modification, they shall submit a 5 stipulation and proposed order for the court’s consideration. 6 7. Pursuant to Local Rule 141.1(f), the court will not retain jurisdiction over 7 enforcement of the terms of this Protective Order after the action is terminated. 8 8. Any provision in the parties’ stipulation that is in conflict with anything in this 9 order is hereby DISAPPROVED. 10 DATED: July 14, 2020 /s/ DEBORAH BARNES 11 UNITED STATES MAGISTRATE JUDGE 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 1 EXHIBIT A 2 ACKNOWLEDGEMENT AND AGREEMENT TO BE BOUND 3 I, ______________________, and read in its entirety and understand the 4 Protective Order that was issued by the United States District Court, for the Eastern 5 District of California, on ________________, 2020, in the case of Denise Wallace v. 6 Nationstar Mortgage, LLC, et al., Case No.: 2:18-cv-02768-JAM-DB. I agree to 7 comply with and be bound by all terms of this Protective Order and I understand and 8 acknowledge that failure to so comply could expose me to sanctions and punishment in 9 the nature of contempt. I solemnly promise that I will not disclose in any manner any 10 information or item that is subject to this Protective Order to any person or entity except 11 in strict compliance with this Protective Order. Further, I solemnly promise that I will 12 not offer to sell, advertise or publicize that I have obtained any protected material 13 subject to this Protective Order. 14 At the conclusion of this matter, I will return all protected materials which came 15 into my possession or control to counsel for the party from whom I received the 16 protected material, or I will destroy those materials pursuant to the procedure as set 17 forth in this Protective Order. I understand that any confidential information contained 18 within any summaries of protected material shall remain protected pursuant to the terms 19 of this Order. 20 21 22 23 24 25 26 27 1 2 I further agree to submit to the jurisdiction of the United States District Court, for 3 the Eastern District of California for the purpose of enforcing the terms of this 4 Protective Order, even if such enforcement proceedings occur after termination of this 5 action. 6 I certify under penalty of perjury that the foregoing is true and correct. 7 Date: ____________________________ 8 City and State where signed: ________________________________ 9 Printed Name: ___________________________________________ 10 Address: ________________________________________________ 11 Signature: _______________________________________________ 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27