Taylor v. C6 Disposal Systems, Inc.

Western District of Texas, txwd-5:2019-cv-00347

MOTION for Protective Order by C6 DISPOSAL SYSTEMS, INC.

Interested in this case?

Current View

Full Text

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION CHARLES TAYLOR, § Civil Action No. 5:19-cv-00347-ESC Individually and on behalf § of all others similarly situated § § JURY TRIAL DEMANDED Plaintiff § § COLLECTIVE ACTION v. § PURSUANT TO 29 U.S.C. § 216(b) § C6 DISPOSAL SYSTEMS, INC. § CLASS ACTION PURSUANT TO § FED. R. CIV. P. 23 Defendant § AGREED MOTION FOR PROTECTIVE ORDER Defendant C6 Disposal Systems, Inc. issued a subpoena for the production of documents to Nonparty Republic Services, Inc. Defendant requests the court enter the attached Agreed Protective Order. It is the court's standard protective order, with only slight modification in order to protect the interests of nonparties such as Republic Services, Inc. as well as those of the parties. Plaintiff has no objections to the protective order. THEREFORE, Defendant C6 Disposal Systems, Inc. requests that the court enter the proposed Protective Order below, and grant it such other relief to which it may be justly entitled. Respectfully submitted, Clausewitz Law Firm, PLLC 2722 West Bitters Road, Suite 110 San Antonio, Texas 78248 Telephone: (210) 762-6422 Facsimile: (210) 762-6988 By: /s/ Tiffanie S. Clausewitz Tiffanie S. Clausewitz State Bar No. 24051936 tiffanie@clausewitzlaw.com Attorneys for Defendant CERTIFICATE OF SERVICE I hereby certify that on October 24, 2019, I electronically filed the foregoing document with the clerk of the court for the U.S. District Court, Western District of Texas, using the electronic case filing system of the court. The electronic case filing system sent a "Notice of Electronic Filing" to the attorneys of record who have consented in writing to accept this Notice as service of this document by electronic means. /s/ Tiffanie S. Clausewitz