Perritt et al v. The Cupcakery, et al

Filing 55

MOTION to Seal Document by Pamela F. Jenkins, The Cupcakery. (Attachments: # 1 Text of Proposed Order)(Slater, Jodie)

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IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS SHERMAN DIVISION RICKY B. PERRITT, Individually; The Cupcakery, LLC, a Texas Limited Liability Company; Buster Baking, LLC, a Texas Limited Liability Company; and the Woodlands Baking, LLC, a Texas Limited Liability Company, Custom Version Corporation, a Texas Corporation, Plaintiffs, v. PAMELA F. JENKINS, Individually; and The Cupcakery, LLC, a Nevada Limited Liability Company, Defendants. § § § § § § § § § § § § § § § § § CAUSE NO. 4:11-CV-23 UNOPPOSED MOTION TO SEAL DEFENDANTS’ MOTION FOR LEAVE TO FILE AMENDED COUNTERCLAIMS Pamela F. Jenkins (“Jenkins”) and The Cupcakery, LLC, a Nevada Limited Liability Company (“Nevada Cupcakery”) (collectively, Jenkins and The Nevada Cupcakery are the “Defendants”), by and through their attorney, hereby move this Court to file their Motion for Leave to File Amended Counterclaims (the “Motion for Leave”) under seal. Defendants’ Motion for Leave and Defendants’ proposed amended counterclaims, which are attached to the Motion for Leave, contain confidential information and/or reference documents already filed under seal. Counsel for Defendants has conferred with counsel for Plaintiffs in this matter, and counsel for Plaintiffs does not oppose this motion. UNOPPOSED MOTION TO SEAL DEFENDANTS’ MOTION FOR LEAVE TO FILE AMENDED COUNTERCLAIMS – Page 1 Accordingly, Defendants respectfully request that this Court grant Defendants’ request to file their Motion for Leave under seal, and for all other and further relief to which they may be entitled. Respectfully submitted, /s/Jodie A. Slater Jodie A. Slater Texas State Bar No. 24046862 STRONG & NOLAN, LLP 1701 N. Market St., Suite 200 Dallas, Texas 75202 (214) 635-5643 (telephone) (214) 752-6929 (telecopy) ATTORNEY FOR DEFEDANTS CERTIFICATE OF CONFERENCE I hereby certify that I conferred with Stephanie Barnes, counsel for Plaintiffs, by telephone regarding this motion pursuant to Local Rule CV-7(h), and counsel for Plaintiffs has indicated she is not opposed to the relief sought in this motion. /s/ Jodie A. Slater Jodie A. Slater UNOPPOSED MOTION TO SEAL DEFENDANTS’ MOTION FOR LEAVE TO FILE AMENDED COUNTERCLAIMS – Page 2 CERTIFICATE OF SERVICE I hereby certify that on the 15th day of April 2011, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following: Michael J. Whitten Michael J. Whitten & Associates, P.C. 218 N. Elm Street Denton, Texas 76201 Clyde M. Siebman Bryan Burg Stephanie Barnes Siebman, Burg, Phillips & Smith, LLP Federal Courthouse Square 300 North Travis Street Sherman, TX 75090 /s/ Jodie A. Slater Jodie A. Slater UNOPPOSED MOTION TO SEAL DEFENDANTS’ MOTION FOR LEAVE TO FILE AMENDED COUNTERCLAIMS – Page 3

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