Janson et al v. LegalZoom.com, Inc.

Filing 41

MOTION for protective order Unopposed Motion for Entry of Stipulated Protective Order and Agreement of Confidentiality filed by James T. Wicks on behalf of LegalZoom.com, Inc.. Suggestions in opposition/response due by 8/16/2010 unless otherwise directed by the court. (Wicks, James)

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Janson et al v. LegalZoom.com, Inc. Doc. 41 IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI CENTRAL DIVISION TODD JANSON, GERALD T. ARDREY, CHAD M. FERRELL, and C & J REMODELING, on behalf of themselves and on behalf of all others similarly situated, Plaintiffs, v. LEGALZOOM.COM, INC., Defendant. DEFENDANT'S UNOPPOSED MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER AND AGREEMENT OF CONFIDENTIALITY Defendant hereby moves this Court for entry of a stipulated Protective Order to facilitate discovery in this case and to protect the disclosure of confidential, personal, private, proprietary and/or competitively sensitive information pertaining to the disclosing parties and individuals who are not parties to this lawsuit. Plaintiffs have indicated their consent to the terms of the Stipulated Protective Order and Agreement of Confidentiality, which will be submitted directly to the Court in accordance with local ECF procedures. WHEREFORE, Defendant requests that the Court enter the Stipulated Protective Order and Agreement of Confidentiality and order that it govern discovery in this case under its terms. Case No. 2:10-cv-04018-NKL KC01DOCS\1006895.1 1 Dockets.Justia.com Respectfully submitted, BRYAN CAVE LLP By: s/ James T. Wicks Robert M. Thompson MO #38156 James T. Wicks MO #60409 One Kansas City Place 1200 Main Street, Suite 3500 Kansas City, MO 64105 Tel.: (816) 374-3200 Fax: (816) 374-3300 John Michael Clear MO #25834 Michael G. Biggers MO #24694 James R. Wyrsch MO #53197 One Metropolitan Square Suite 3600 211 North Broadway St. Louis, MO 63102 Tel.: (314) 259-2000 Fax: (314) 259-2020 Attorneys for LegalZoom.com, Inc. CERTIFICATE OF SERVICE I hereby certify that on July 29, 2010, I electronically filed the above and foregoing with the clerk of court using the CM/ECF system, which will send notice of electronic filing to all counsel of record. s/ James T. Wicks Attorney for Defendant KC01DOCS\1006895.1 2

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