Corbin Bernsen v. Innovative Legal Marketing, LLC

Filing 16

MOTION for Protective Order by Innovative Legal Marketing, LLC. (Attachments: # 1 Exhibit Proposed Protective Order)(Paul, Dustin)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF VIRGINIA
Norfolk Division

CORBIN BERNSEN,
Plaintiff and Counterclaim Defendant,
v.

Civil Action No. 2:11cv546

INNOVATIVE LEGAL MARKETING, LLC,
Defendant and Counterclaim Plaintiff.
MOTION AND BRIEF FOR ENTRY OF AN AGREED PROTECTIVE ORDER

NOW COMES Defendant and Counterclaim Plaintiff Innovative Legal Marketing, LLC,
by counsel, and for its Motion and Brief for Entry of an Agreed Protective Order states as
follows:
1. In order to protect the privacy of the Parties and Third-Parties, the confidentiality of their
legitimate business interests and other non-public, competitively sensitive, proprietary,
trade secret or confidential business information, and to permit discovery and trial
preparation to proceed with a minimum of discovery motions over matters of
confidentiality, the parties have negotiated an agreed protective order that they propose
the Court enter in this matter.
2. The Proposed Order is attached as Exhibit A and has been agreed to by counsel for both
parties.
WHEREFORE ILM respectfully requests the Court enter the agreed proposed Order in
this matter.

INNOVATIVE LEGAL MARKETING, LLC
/s Dustin Paul

Richard H. Ottinger
Virginia State Bar #38842
Dustin M. Paul
Virginia State Bar #75287
Counsel for Innovative Legal Marketing, LLC
[e-mail]
[e-mail]
Vandeventer Black, L.L.P.
500 World Trade Center
Norfolk, Virginia 23510-1699
[phone]
[phone] – facsimile

.

CERTIFICATE OF SERVICE
I hereby certify that on Friday, March 30, 2012, I will file the foregoing in ECF which
will serve a copy on those parties listed below:
J. Douglas Baldridge
Virginia State Bar # 34327
[e-mail]
Lauren E. Ingebritson
(Not admitted in Virginia)
[e-mail]
Molly T. Geissenhainer
Virginia State Bar # 78508
[e-mail]
VENABLE LLP
Counsel for Plaintiff, Corbin Bernsen
575 Seventh Street, N.W.
Washington, D.C. 20004
202-344-4000 (telephone)
202-344-8300 (facsimile)
Counsel for Plaintiff Corbin Bernsen
/s Dustin Paul
Richard H. Ottinger, Esquire
Virginia State Bar #38842
Dustin M. Paul
Virginia State Bar #75287
Counsel for Innovative Legal Marketing, LLC
[e-mail]
Vandeventer Black, L.L.P.
500 World Trade Center
Norfolk, Virginia 23510-1699
[phone]
[phone] – facsimile

.