Mirror Worlds, LLC v. Apple, Inc.

Filing 102

Agreed MOTION For Entry of Revised Agreed Protective Order re 99 Order on Motion to Amend/Correct, by Mirror Worlds, LLC. (Attachments: # 1 Text of Proposed Order)(Race, Deborah)

Mirror Worlds, LLC v. Apple, Inc. Doc. 10 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC Plaintiff, Civil Action No. 6:08-CV-88 LED JURY TRIAL DEMANDED v. APPLE, INC. Defendant. MOTION FOR ENTRY OF REVISED AGREED PROTECTIVE ORDER PURSUANT TO THE COURT'S ORDER OF JULY 8, 2009 Pursuant to the Court's Order of July 8, 2009, Mirror Worlds, LLC herewith submits an agreed version of the proposed protective order, attached as Exhibit A, that includes the safeguards Magistrate Judge Love described in his recent opinion in Document Generation Corp. v. Allscripts, LLC, 6:08cv479, 2009 WL 1766096 (E.D. Tex. June 23, 2009). Counsel for Mirror Worlds, LLC has conferred with counsel for Apple, Inc., and Apple has no objection to entry of the revised Agreed Protective Order. Accordingly, Mirror Worlds, LLC respectfully requests that the Court enter the attached revised protective order. Respectfully submitted, BY: /s/ Deborah Race Otis Carroll, Lead Counsel Texas States Bar No. 03895700 Deborah Race Texas State Bar No. 16448700 -1- Dockets.Justia IRELAND CARROLL & KELLEY, P.C. 6101 S. Broadway, Suite 500 Tyler, Texas 75703 Tel: (903) 561-1600 Fax: (903) 581-1071 Email: Fedserv@icklaw.com OF COUNSEL: Joseph Diamante (Pro Hac Vice) Kenneth L. Stein (Pro Hac Vice) Richard H. An (Pro Hac Vice) STROOCK & STROOCK & LAVAN LLP 180 Maiden Lane New York, N.Y. 10038 Tel: (212) 806-5400 Fax: (212) 806-6006 ATTORNEYS FOR PLAINTIFF, Email: kstein@stroock.com Email: ran@stroock.com MIRROR WORLDS, LLC CERTIFICATE OF CONFERENCE Pursuant to Local Rule CV-7(h), movant has contacted opposing counsel and was informed that opposing counsel agrees to the relief requested herein. /s/ Deborah Race Attorney for Movant -2- CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document this 29th th day of July, 2009, via the Court's CM/ECF system per Local Rule CV-5(a)(3). /s/ Deborah Race -3-