American Airlines Inc v. Travelport Limited et al

Filing 147

STIPULATED SUPPLEMENTAL PROTECTIVE ORDER: The Court ORDERS, as follows: (1) Concur Discovery Material designated as "Confidential-Outside Counsel's Eyes Only" or "Highly Confidential" shall be construed as equivalent to "Outside Attorneys' Eyes Only Information" in paragraphs 6, 11, 12(a)-(e), 13 and 14 of the Protective Order; and (2) Concur Discovery Material produced in response to the subpoena duces tecum issued by American in American Airlines, Inc. v. Sabre, Inc. et al., 67th Judicial District Court, Tarrant County, Texas, No. 067-249214-10 ("the State Proceeding") under the terms of the protective orders entered in the State Proceeding on January 24, 2011, and August 8, 2011, may also be used in this proceeding. (Ordered by Judge Terry R Means on 10/17/2011) (klm)

UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
FORT WORTH DIVISION
AMERICAN AIRLINES, INC.
Plaintiff,
v.
SABRE, INC., ET AL.
Defendants.

§
§
§
§
§
§
§
§
§
§

CIVIL ACTION NO. 4:11-CV-244-Y

STIPULATED SUPPLEMENTAL PROTECTIVE ORDER
Pursuant to the stipulation of plaintiff American Airlines, Inc. (“American”), and non-party
Concur Technologies, Inc. (“Concur”), upon which American has issued a Subpoena to Produce
Documents, Information, or Objects or to Permit Inspection of Premises in a Civil Action dated July
5, 2011 (“the Subpoena”), Concur’s production of documents and information in response to the
Subpoena and any additional discovery requests that may be served by American upon Concur in
this matter (“Concur Discovery Material”) shall be governed by the protective order entered on
August 15, 2011 (doc. 130) (“the Protective Order”).
In addition to the protections and provisions set forth in the Protective Order, which is
wholly incorporated herein by reference, American and Concur have further stipulated, and thus the
Court ORDERS, as follows: (1) Concur Discovery Material designated as “Confidential-Outside
Counsel’s Eyes Only” or “Highly Confidential” shall be construed as equivalent to “Outside
Attorneys’ Eyes Only Information” in paragraphs 6, 11, 12(a)-(e), 13 and 14 of the Protective Order;
and (2) Concur Discovery Material produced in response to the subpoena duces tecum issued by
American in American Airlines, Inc. v. Sabre, Inc. et al., 67th Judicial District Court, Tarrant

County, Texas, No. 067-249214-10 (“the State Proceeding”) under the terms of the protective orders
entered in the State Proceeding on January 24, 2011, and August 8, 2011, may also be used in this
proceeding.
Unless this order includes a clause that explicitly states that a particular local civil rule
is modified as applied to this case, nothing in this order shall be construed to modify the
provisions, operation, or effect of any local civil rule of this Court.
SIGNED October 17, 2011.

____________________________
TERRY R. MEANS
UNITED STATES DISTRICT JUDGE

Respectfully submitted,

/s/ Michelle Hartmann

/s/ Jennifer J. Johnson

Michelle Hartmann

Jennifer J. Johnson (CSB No. 252897)

State Bar No. 24032401

Rodger R. Cole (CSB No. 178865)

WEIL, GOTSHAL & MANGES LLP

FENWICK & WEST LLP

200 Crescent Court, Suite 300

555 California Street, Floor 12

Dallas, Texas 75201-6950

San Francisco, California 94104

214.746.7700

415.875.2300

214.746.7777 (fax)

415.281.1350 (fax)

Richard A. Rothman

ATTORNEYS FOR NON-PARTY
CONCUR TECHNOLOGIES, INC.

WEIL, GOTSHAL & MANGES LLP
767 Fifth Avenue
New York, New York 10153
212.310.8426
212.310.8285 (fax)

Bill F. Bogle
State Bar No. 02561000
Roland K. Johnson
State Bar No. 00000084
HARRIS, FINLEY & BOGLE, P.C.
777 Main Street, Suite 3600
Fort Worth, Texas 76102