Timebase Pty Ltd v. Thomson Corporation, The

Filing 192

MOTION for Protective Order by Thomson Corporation, The, West Publishing Corporation, West Services. (Razavi, Katherine)

Timebase Pty Ltd v. Thomson Corporation, The

Doc. 192

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA TIMEBASE PTY LTD., Plaintiff, vs. THE THOMSON CORPORATION, WEST PUBLISHING CORPORATION, and WEST SERVICES, INC., Defendants. MOTION The defendants collectively move for a protective order under Federal Rule of Civil Procedure 26(c) precluding the plaintiff, TimeBase Pty Ltd, from deposing defendants' attorney, Mr. Mark Stignani. The basis for the motion is that Mr. Stignani is in-house litigation counsel for the defendants. Information regarding all of the topics on which TimeBase seeks to depose Mr. Stignani may be obtained from other sources, is not relevant or is privileged, and/or is not crucial to the preparation of TimeBase' case. s This motion is based on the accompanying Memorandum in Support of Defendants' Motion for Protective Order, Declarations, Exhibits, and the files, records, and proceedings in this case. DEFENDANTS' MOTION FOR PROTECTIVE ORDER Civil No. 07-1687 (JNE/JJG)

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Dated: October 11, 2010

FAEGRE & BENSON LLP By: /s/ Mary V. Sooter David J.F. Gross #208772 Calvin L. Litsey #153746 Theodore M. Budd #314778 Mary V. Sooter (pro hac vice) Kevin P. Wagner #034008X Katherine S. Razavi #388958 2200 Wells Fargo Center 90 South Seventh Street Minneapolis, Minnesota 55402 Telephone: [phone] Fax: [phone] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Email: [e-mail] Attorneys for Defendants The Thomson Corporation, West Publishing Corporation, and West Services, Inc.