Day v. Sierra Services, LLC

Western District of Texas, txwd-5:2019-cv-00066

Joint MOTION for Entry of Confidentiality and Protective Order by Sierra Services, LLC. Motions referred to Judge Henry J. Bemporad.

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION SHELDON DAY, Individually and § On Behalf of All Others Similarly § Situated, § § Plaintiff, § § v. § NO. 5:19-CV-00066 § SIERRA SERVICES, LLC, § § Defendant. § AGREED MOTION FOR ENTRY OF CONFIDENTIALITY AND PROTECTIVE ORDER Defendant Sierra Services, LLC, and Plaintiff Sheldon Day (the "Parties") submit this Agreed Motion for Entry of Confidentiality and Protective Order (the "Agreed Motion"). In support of the Agreed Motion, the Parties submit to the Court the following: The Parties anticipate that the disputes between them will include the discovery into and disclosure of information that is confidential and proprietary to one or more of the Parties and/or non-parties. In order to facilitate the discovery into and to protect against the disclosure of such information that is believed in good faith to represent or contain confidential information, the Parties have prepared and approved the form of the Confidentiality and Protective Order attached hereto as Exhibit A. WHEREFORE, the foregoing considered, the Parties request that the Court enter the Confidentiality and Protective Order attached hereto as Exhibit A for all purposes of this case. Page 1 of 2 CERTIFICATE OF SERVICE I hereby certify that on July 31, 2019, I served this document on all parties or their attorney(s) of record, who are listed below, in accordance with Rule 5(b): Melissa Moore Curt Hesse Bridget Davison MOORE & ASSOCIATES Lyric Centre 440 Louisiana Street, Suite 675 Houston, Texas 77002 Melissa@mooreandassociates.net Curt@mooreandassociates.net Bridget@mooreandassociates.net __/s/ Adam C. Kiehne______________________ Adam C. Kiehne Page 3 of 3