John Beck Amazing Profits, LLC v. Google Inc. et al

Filing 37

Agreed MOTION for Protective Order by Google Inc., AOL LLC. (Attachments: # 1 Text of Proposed Order)(Babcock, Charles)

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John Beck Amazing Profits, LLC v. Google Inc. et al Doc. 37 UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION THE RODNEY A. HAMILTON LIVING TRUST and JOHN BECK AMAZING PROFITS, LLC, Individually and on Behalf of All Others Similarly Situated, Plaint iffs, v. (1) GOOGLE, INC.; AND (2) AOL, LLC Defendants. Civil Action No. 2:09-cv-00151-TJW-CE CLASS ACTION COMPLAINT JURY TRIAL REQUESTED AGREED MOTION FOR ENTRY OF PROPOSED AGREED PROTECTIVE ORDER Plaint iffs John Beck Amazing Profits, LLC and The Rodney A. Hamilton Living Trust (collectively "Plaintiffs") and Defendants Google Inc. and AOL LLC (collectively "Defendants") hereby move the Court to enter their proposed Agreed Protective Order, and would respectfully show the Court the following: The parties have agreed upon the entry of the protective order attached hereto as Exhibit "A." Accordingly, Plaintiffs and Defendants respectfully request that the Court enter the Agreed Protective Order being submitted herewith. WHEREFORE, PREMISES CONSIDERED, the parties respectfully request that the Court grant this Motion and enter their proposed Agreed Protective Order. Agreed Motion for Entry of Proposed Agreed Protective Order Page 1 Dockets.Justia.com Respect fully submitted, /s/ Marc A. Fenster ______________ Marc A. Fenster, CA Bar # 181067 RUSS, AUGUST & KABAT 12424 Wilshire Boulevard 12th Floor Los Angeles, California 90025 Telephone: 310/826-7474 Facsimile: 310/826-6991 Email: mfenster@raklaw.com ATTORNEYS FOR JOHN BECK AMAZING PROFITS, LLC AND THE RODNEY A. HAMILTON LIVING TRUST /s/ Charles L. Babcock____________ Charles L. "Chip" Babcock Texas State Bar No. 01479500 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-6030 (214) 953-5822- Fax Email: cbabcock@jw.com David T. Moran Texas State Bar No. 14419400 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-6051 (214) 661-6677 - Fax Email: dmoran@jw.com Carl C. Butzer Texas State Bar No. 03545900 JACKSON WALKER L.L.P. 901 Main Street, Suite 6000 Dallas, Texas 75202 (214) 953-5902 (214) 661-6609 - Fax Email: cbutzer@jw.com ATTORNEYS FOR DEFENDANTS GOOGLE INC. AND AOL LLC Agreed Motion for Entry of Proposed Agreed Protective Order Page 2 CERTIFICATE OF SERVICE I hereby certify that on February 15, 2010, I electronically submitted the foregoing document with the clerk of the court for the U.S. District Court, Eastern District of Texas, using the electronic case files system of the court. The electronic case files system sent a "Notice of Electronic Filing" to individuals who have consented in writing to accept this Notice as service of this document by electronic means. All other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by first class mail today, February 15, 2010. /s/ Charles L. Babcock Charles L. Babcock Agreed Motion for Entry of Proposed Agreed Protective Order Page 3