Whitmill v. Warner Bros. Entertainment Inc.

Filing 21

Joint MOTION for Protective Order by Defendant Warner Bros. Entertainment Inc.. (Attachments: # 1 Exhibit A)(Sableman, Mark)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF MISSOURI
EASTERN DIVISION
S. VICTOR WHITMILL,

)
)
Plaintiff, )
)
v.
)
)
WARNER BROS. ENTERTAINMENT, INC.,
)
)
Defendant. )

Civil Action No. 4:11-cv-752
Judge Catherine D. Perry

JOINT MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER
Plaintiff S. Victor Whitmill and Defendant Warner Bros. Entertainment, Inc., by their
respective attorneys, move this Court for entry of an Agreed Protective Order. In support of their
motion, the parties state as follows:
1.

The parties have certain documents and information responsive to discovery

requests or relevant to the case the unrestricted use of which would be harmful to the producing
party or that the producing party is obligated to maintain as confidential.
2.

The parties have agreed that such documents and information shall remain

confidential and have prepared and executed an Agreed Protective Order which sets forth the
procedures for production, disclosure and use of information designated as confidential by either
party.
3.

The Agreed Protective Order is attached to this Motion as Exhibit A.

WHEREFORE, the parties request that this Court enter the Agreed Protective
Order attached as Exhibit A.
AGREED:
/s/ Michael A. Kahn
Michael A. Kahn (#35411MO)
Pete Salsich III (#44886MO)
Geoff G. Gerber (#47097MO)
THE BRICKHOUSE LAW GROUP, PC
1006 Olive Street, Suite 303
St. Louis, MO 63101-1070
Attorneys for Plaintiff, S. Victor Whitmill
/s/ Mark Sableman
Mark Sableman (#36276MO)
THOMPSON COBURN LLP
One US Bank Plaza
St. Louis, MO 63101
[phone]
Frederick J. Sperling (IL3128237)
Sondra A. Hemeryck (IL6207039)
SCHIFF HARDIN LLP
233 South Wacker Drive
Suite 6600
Chicago, IL 60606
[phone]
Attorneys for Defendant,
Warner Bros. Entertainment, Inc.

-2-

CERTIFICATE OF SERVICE
I hereby certify that on May 18, 2011 I electronically filed the foregoing Joint Motion for
Entry of Agreed Protective Order with the Clerk of the Court using the CM/ECF system, which
will cause an electronic copy to be served on counsel of record.
/s/ Mark Sableman
Mark Sableman

CH2\9937330.2