Netquote Inc. v. Byrd

Filing 36

Netquote Inc. v. Byrd

Doc. 36

Case 1:07-cv-00630-DME-MEH

Document 36

Filed 06/15/2007

Page 1 of 4

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 07-cv-00630-DME-MEH NETQUOTE, INC., a Colorado corporation, Plaint iff, v. BRANDON BYRD, an internet user making use of the IP Addresses 64.136.27.226 and 64.136.26.227, and MOSTCHOICE.COM, INC., a Georgia corporation, Defendants. STIPULATED MOTION FOR PROTECTIVE ORDER Plaint iff NetQuote, Inc. (" etQuote) and Defendant Brandon Byrd, through their N respective counsel, pursuant to Fed .R. Civ. P. 26(c), hereby jointly move for the entry of the Stipulated Protective Order that is submitted herewith. In support thereof, the parties state as fo llo ws: 1. Plaintiff NetQuote has requested to make a forensic image of Brandon Byrd' s

hard drive for evidence relevant to the above-captioned lawsuit; 2. Defendant Brandon Byrd (" yrd" initially objected to NetQuote' Request B ) s

which resulted in the parties meeting and conferring concerning the concerns Byrd had about disclosing personal information on his computer hard drive;

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Dockets.Justia.com

Case 1:07-cv-00630-DME-MEH

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Filed 06/15/2007

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3.

The parties raised this issue with the Court at the scheduling conference on this

matter on June 4, 2007; 4. ten days; 5. The parties met and conferred concerning a proposed protective order and agreed The Court directed the parties to agree on the terms of a protective order within

to the terms of such an order; and 6. The parties'proposed protective order is being submitted along with this motion.

WHERE FORE, the parties jointly request that the Court enter the proposed Stipulated Protective Order in the form submitted with this Motion for the reasons set forth above and at the scheduling conference in this matter.

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DATED: June 15, 2007 _s/ David W. Stark_ David W. Stark FAEGRE & BENSON LLP 3200 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Daniel D. Williams FAEGRE & BENSON LLP 1900 Fifteenth Street Boulder, Colorado 80302 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] _s/ Ryan L. Isenberg__ Ryan L. Isenberg ISENBERG & HEWITT, P.C. 7000 Peachtree Dunwoody Road, Bldg 15, Suite 100 At lanta, Georgia 30328 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Tracy L. Ashmore Rachel L. Eichenbaum HOLME ROBERTS & OWENS LLP 4400 Wells Fargo Center 1700 Lincoln Street Denver, Colorado 80203 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] Counsel for Defendants

Counsel for Plaintiff

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Filed 06/15/2007

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CERTIFICATE OF SERVICE I certify that on this 15th day of June, 2007, I electronically filed the foregoing STIPULATED PROTECTIVE ORDER RE: BANDON BYRD' HARD DRIVE with the S Clerk of Court using the CM/ECF system, which will send notification of such filing to the fo llo wing counsel of record: Ryan L. Isenberg, Esq. ISENBERG & HEWITT, P.C. 7000 Peachtree Dunwoody Road, Bldg 15, Suite 100 At lanta, GA 30328 [e-mail] Tracy L. Ashmore, Esq. Rachel L. Eichenbaum, Esq. HOLME ROBERTS & OWENS LLP 1700 Lincoln Street, Suite 4100 Denver, CO 80203 [e-mail] m [e-mail] s/Cecil A. Kennedy_______

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