Pearson v. Colt Oilfield Services, LLC et al

Western District of Texas, txwd-5:2018-cv-01029

Joint MOTION for Entry of Confidentiality and Protective Order by Roy E Aguilar, Colt Oilfield Services, LLC.

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UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION DOUGLAS PEARSON and JAMES § ADKINS, Individually And On Behalf § Of All Others Similarly Situated Under§ 29 U.S.C. §216(b), § PLAINTIFFS, § § V. § Civil Action No. 5:18-CV-1029-OLG § COLT OILFIELD SERVICES, LLC, and § ROY E. (EDDIE) AGUILAR, § DEFENDANTS. § JOINT MOTION FOR CONFIDENTIALITY AND PROTECTIVE ORDER COME NOW Plaintiffs Douglas Pearson and James Adkins, Individually and on behalf of All Others Similarly Situated (collectively "Plaintiffs"), and Defendants Colt Oilfield Services, LLC and Roy E. (Eddie) Aguilar (collectively "Defendants"), and file their Joint Motion for Confidentiality and Protective Order ("Motion") seeking the entry of the approved form of the "Western District Confidentiality and Protective Order" ("Protective Order") provided for use pursuant to Local Rule CV-26(c) and Appendix H to those Local Rules to protect confidential and proprietary information. In support, Plaintiffs and Defendants respectfully show the Court the following: In this employment lawsuit, Plaintiffs allege, inter alia, that Defendants violated the Fair Labor Standards Act of 1938 ("FLSA"). In light of the anticipated exchange of documents and information, counsel for Plaintiffs and Defendants have discussed entry of the Protective Order in order to protect any confidential and proprietary information and/or documentation that may be sought by the parties in discovery. WHEREFORE, PREMISES CONSIDERED, the Parties request that this Court grant this Motion and grant such other and further relief to which the Court finds that the Parties may be justly entitled. Respectfully submitted, /s/ Jack Siegel with permission JACK SIEGEL Attorney in Charge Texas Bar No. 24070621 SIEGEL LAW GROUP PLLC 2820 McKinnon, Suite 5009 Dallas, Texas 75201 Telephone: 214.790.4454 Email: ATTORNEYS FOR PLAINTIFF /s/ Melissa Morales Fletcher Melissa Morales Fletcher Of Counsel State Bar No. 24007702 Email: THE MORALES FIRM, P.C. 6243 IH 10 West, Suite 132 San Antonio, Texas 78201 Telephone: (210) 225-0811 Facsimile: (210) 225-0821 GOODE CASSEB JONES RIKLIN CHOATE & WATSON, P.C. KYLE WATSON Texas Bar No. 20971100 Jenna C. Castleman Texas Bar No. 24105583 2122 N. Main Avenue San Antonio, Texas 78212 Tel: (210) 733-6030 Fax: (210) 733-0330 ATTORNEYS FOR DEFENDANTS CERTIFICATE OF SERVICE I do hereby certify that on 5/2/19, I electronically filed the foregoing with the Clerk of the Court using the CM-ECF system, which will send notification of such filing to the following: Jack Siegel Travis Hedspeth /s/ Melissa Morales Fletcher Melissa Morales Fletcher