Koschitzki v. Apple Inc. et al

Filing 59

MOTION for Protective Order by AT&T Mobility LLC. (Attachments: # 1 Memorandum in Support Memorandum of Law in Support of Motion of AT&T Mobility LLC for a Protective Order, # 2 Affidavit Supplemental Declaration of TJ Terry, # 3 Exhibit Exhibit to Supplemental Terry Declaration) (Ranlett, Kevin)

Koschitzki v. Apple Inc. et al

Doc. 59

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK AVI KOSCHITZKI, on Behalf of Himself and all Others Similarly Situated, Plaintiff, v. APPLE INC. and AT&T MOBILITY LLC, Defendants. NOTICE OF MOTION AND MOTION OF AT&T MOBILITY LLC FOR A PROTECTIVE ORDER TO: ALL PARTIES IN INTEREST: PLEASE TAKE NOTICE THAT, defendant AT&T Mobility LLC ("ATTM") will respectfully move this court, before the Honorable Viktor V. Pohorelsky, United States District Magistrate Judge, Eastern District of New York, at the United States Courthouse, 225 Cadman Plaza East, Brooklyn, New York, on February 23, 2009 at 3:00 p.m., pursuant to Federal Rule of Civil Procedure 26(c), for a protective order barring plaintiff Avi Koschitzki from taking the noticed depositions of Carolina Mahone-Gonzalez, Adam Gill, Richard Nagareda, and TJ Terry. In support of this Motion, ATTM relies upon its supporting Memorandum of Law and the Supplemental Declaration of TJ Terry, which are being filed concurrently herewith. Dated: February 23, 2008 Respectfully submitted, /s Kevin Ranlett Evan M. Tager (of counsel) Archis A. Parasharami (pro hac vice) Kevin Ranlett (pro hac vice) MAYER BROWN LLP 1909 K St., NW Washington, DC 20006 Case No. 1:08-cv-04451-JBW-VVP

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[phone] Steven D. Greenblatt (SG ­ 5105) CROWELL & MORING LLP 153 East 53rd Street, 31st Floor New York, NY 10022 [phone] Kathleen Taylor Sooy (pro hac vice) Lynn E. Parseghian (pro hac vice) CROWELL & MORING LLP 1001 Pennsylvania Ave., NW Washington, DC 20004 [phone] Counsel for Defendant AT&T Mobility LLC

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