Landry-Bell v. Various Inc et al

Filing 52

Joint MOTION for Protective Order by Zach Wilhelm and Shelly Landry-Bell. (aty,Odom, John) Modified on 8/9/2007 to add filer (Smith, C).

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Landry-Bell v. Various Inc et al Doc. 52 Case 5:05-cv-01526-TS-MLH Document 52 Filed 08/09/2007 Page 1 of 3 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA SHREVEPORT DIVISION SHELLY LANDRY-BELL VERSUS VARIOUS, INC. and ZACH WILHELM CIVIL ACTION NO. CV05-1526 S JUDGE STAGG MAGISTRATE JUDGE HORNSBY JOINT MOTION FOR A PROTECTIVE ORDER (EXPEDITED REQUEST FOR CONSIDERATION IN LIGHT OF SCHEDULED DISCOVERY) NOW INTO COURT, through undersigned counsel, come Plaintiff Shelly LandryBell and Defendant Zachary Wilhelm and move the Court for a protective order as follows: 1. Plaintiff's counsel has subpoenaed from America Online ("AOL") certain records that may or may not exist concerning accounts in the name of Defendant Zachary Wilhelm. Plaintiff has subpoenaed from AOL credit card account numbers that may have been utilized by Defendant Wilhelm to pay for any AOL accounts he may have held. The subpoenas duces tecum issued by Plaintiff's counsel are returnable on August 22, 2007 at the AOL headquarters in Dulles, Virginia. 2. Defendant Wilhelm is concerned about any credit card information that may be in the hands of AOL being disseminated widely for obvious financial privacy and security reasons. Dockets.Justia.com Case 5:05-cv-01526-TS-MLH Document 52 Filed 08/09/2007 Page 2 of 3 3. After consultation with undersigned counsel, Plaintiff's counsel has agreed to the entry of a protective order by which any information concerning credit card accounts in the name of or associated with Zachary Wilhelm which are obtained during discovery in this case shall not be filed in the record except under seal and that such information shall not be released or divulged to anyone other than counsel for the parties, any expert consultants retained by counsel for any of the parties, the credit card issuing company involved (in the event Plaintiff seeks further information concerning any credit card accounts disclosed during discovery the account numbers for which are in the name of or associated with Zachary Wilhelm), Defendants Wilhelm and Various, Inc. and necessary court personnel (including court reporters during discovery depositions). 4. Defendant Various, Inc. does not join in this Joint Motion but has indicated, through counsel, that they do not oppose the entry of the protective order being sought herein. WHEREFORE Plaintiff and Defendant Zachary Wilhelm pray that the Court enter a protective order in the form and substance of the attached order, which has been reviewed by and approved by all parties to the captioned matter. Respectfully submitted, 509 Market Street, 7th Floor United Mercantile Bank Building Shreveport, LA 71101 (318) 221-6444 fax (318) 221-6555 BJKS1507@aol.com BODENHEIMER, JONES & SZWAK, LLP BY:__/signed/______________________ DAVID A. SZWAK, La. Bar No. 21157 Counsel for Plaintiff, SHELLY LANDRY-BELL Case 5:05-cv-01526-TS-MLH Document 52 Filed 08/09/2007 Page 3 of 3 2124 Fairfield Avenue Shreveport, LA 71104 (318) 221-1600 fax (318) 425-1256 john.odom@jodplaw.com JONES, ODOM, DAVIS & POLITZ, L.L.P. BY:_____/signed/_____________________ JOHN S. ODOM, JR., La. Bar No. 10163 Counsel for Defendant, ZACH WILHELM CERTIFICATE OF SERVICE I certify that copies of the foregoing Joint Motion for a Protective Order have been served on all counsel of record by the ECF notification system of the United States District Court for the Western District of Louisiana, on August 9, 2007. ____/signed/__________________ John S. Odom, Jr. Counsel for Zachary Wilhelm

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