Steinbuch v. Cutler et al
MOTION for Protective Order by Hyperion Books. (Deere, Beth)
Steinbuch v. Cutler et al
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UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF ARKANSAS ROBERT STEINBUCH v. PLAINTIFF Case No.: 4-06 CV 0000 620-WRW
JESSICA CUTLER AND HYPERION BOOKS AND DISNEY PUBLISHING WORLDWIDE AND HOME BOX OFFICE AND TIME WARNER
MOTION FOR PROTECTIVE ORDER Separate defendant Hyperion, an imprint of Buena Vista Books, Inc. ("BVB"), for its Motion for Protective Order, states: 1. BVB has filed, under seal, an exhibit attached to its Motion to Dismiss.
The exhibit is a copy of an agreement (the "Agreement") between BVB and Time Warner Book Group, Inc. (now Hachette Book Group, USA), for the distribution of The Washingtonienne, the book at issue in this lawsuit. 2. The Agreement, attached as Exhibit 1 to the Affidavit of Sharon Kitter,
contains a confidentiality clause. Therefore, its use should be limited to this action, and it should not be used by any party or attorney for any business, commercial, competitive or any other purpose whatsoever, except with the prior written consent of BVB or upon prior Order of this Court.
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Furthermore, parties and attorneys, including their employees, should be
prohibited from distributing the Agreement without first obtaining BVB's written consent or a court order. WHEREFORE, BVB prays that its motion be granted and that the Court enter a protective order limiting use of the Agreement to this lawsuit and prohibiting distribution of the Agreement by parties and their attorneys. WILLIAMS & ANDERSON PLC 111 Center Street Twenty-Second Floor Little Rock, Arkansas 72201 (501) 372-0800 (501) 372-6453 (facsimile) E-mail: firstname.lastname@example.org By: /s/ Beth Deere__ Philip S. Anderson, Ark. Bar # 60001 Jess Askew III, Ark. Bar # 86005 Beth Deere, Ark. Bar #86050 Clayborne S. Stone, Ark. Bar # 2003102
Attorneys for Separate Defendant Hyperion, an imprint of Buena Vista Books, Inc.
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CERTIFICATE OF SERVICE I certify that on this 13th day of September 2006, I served a copy of the foregoing document via the Court's ECF/Pacer electronic filing system upon the following persons: Jonathan Rosen, Esquire 1645 Lamington Road Bedminster, NJ 07921
Attorney for Plaintiff Claire Hancock, Esquire M.N. Norton, Esquire Gary D. Marts, Esquire Wright, Lindsey & Jennings 200 West Capitol Avenue, #2200 Little Rock, AR 72201
email@example.com firstname.lastname@example.org email@example.com
Attorneys for Separate Defendants Time Warner and Home Box Office __/s/ Beth Deere ___________________ Beth Deere
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