ECeipt LLC v. Old Navy, LLC

Western District of Texas, txwd-6:2019-cv-00258

Unopposed MOTION for Protective Order by eCeipt LLC.

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UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION ECEIPT LLC, Case No. 6:19-cv-00258-ADA Plaintiff JURY TRIAL DEMANDED v. OLD NAVY, LLC, Defendant UNOPPOSED MOTION FOR ENTRY OF PROTECTIVE ORDER Pursuant to Federal Rule of Civil Procedure 26(c) and Local Rule CV-26, Plaintiff, eCeipt LLC, moves for entry of the unopposed Protective Order that is attached as Exhibit 1. Plaintiff believes that this action will involve exchanging information between the parties and the production of information by non-parties that the disclosing party considers to be sensitive, confidential, and/or proprietary, such as non-public business records, non-public personal information of non-parties, and nonpublic financial information. Such information is valuable at least because it is not generally known to the public nor shared between the parties or their competitors. There is therefore good cause to enter the unopposed Protective Order to protect such information. Accordingly, Plaintiff respectfully requests that the Court enter the Protective Order. Counsel for Plaintiff has conferred with counsel for Defendant and counsel stated the Defendant is not opposed to the Motion and entry of the Protective Order. Dated: June 6, 2019 Respectfully Submitted /s/ Raymond W. Mort, III Raymond W. Mort, III Texas State Bar No. 00791308 THE MORT LAW FIRM, PLLC 100 Congress Ave, Suite 2000 Austin, Texas 78701 Tel/Fax: (512) 865-7950 ATTORNEYS FOR PLAINTIFF UNOPPOSED MOTION FOR ENTRY OF PROTECTIVE ORDER PAGE | 2