Rude Music Inc v. Newt 2012, Inc. et al

Filing 35

MOTION by Plaintiff Rude Music Inc for protective order (agreed) (Attachments: # 1 Exhibit 1)(Holzhall, Marianne)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS

RUDE MUSIC, INC.,
Plaintiffs,
v.
NEWT 2012, INC.,NEWT
GINGRICH, and AMERICAN
CONSERVATIVE UNION,
Defendants.

)
)
)
)
) Case No. 12 cv 640
)
) Judge Kennelly
) Magistrate Judge Finnegan
)
)
)
)
)

AGREED MOTION FOR ENTRY OF A PROTECTIVE ORDER
Plaintiff Rude Music, Inc., pursuant to Federal Rules of Civil Procedure
26(c)(1), moves for entry of a protective order governing discovery in this case.
1.
defendants’

This is an action for copyright infringement, arising from the
alleged

infringement

of

the

plaintiff’s

copyrighted

musical

composition, “Eye of the Tiger.”
2.

The parties anticipate that discovery in this action will involve the

exchange of confidential personal or financial and other commercially sensitive
data that is not publicly known. The parties have agreed on the terms of a
proposed protective order, which is attached as Exhibit 1. Its provisions, for the
most part, track those in the form protective order approved for use in patent
cases in this district. See LPR 1.4 and Appendix B.

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WHEREFORE, for the foregoing reasons, Rude Music asks that the Court
enter the protective order as attached or with modifications as the Court deems
appropriate.

Respectfully submitted,
/s/ Marianne C. Holzhall
Annette M. McGarry (#6205751)
[e-mail]
Marianne C. Holzhall (#6204057)
[e-mail]
McGarry & McGarry, LLC
120 North LaSalle Street, Suite 1100
Chicago, IL 60602
[phone]
Attorneys for Rude Music, Inc.

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CERTIFICATE OF SERVICE
I hereby certify that on March 21, 2012, the foregoing Plaintiff’s Motion for
Entry of a Protective Order was electronically filed using the CM/ECF system and
served upon:
Karl Braun
Byron Lindberg
Hall, Booth, Smith & Slover, PC
611 Commerce Street, Suite 2925
Nashville, TN 37203
Brian A. Rosenblatt
Darren P. Grady
Kyra E. Flores
SmithAmundsen LLC
150 North Michigan Avenue, Suite 3300
Chicago, IL 60601
Brian E. Cohen
Steven F. Pflaum
Neal, Gerber & Eisenberg
2 North LaSalle Street, Suite 1700
Chicago, IL 69602
Thomas Kirby
Wiley Rein LLP
1776 K Street N.W.
Washington, DC 20006

/s/ Marianne C. Holzhall

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