Amiga Inc v. Hyperion VOF

Filing 114

Stipulated MOTION for Protective Order by Counter Claimants Hyperion VOF, Hyperion VOF, Counter Defendants Amiga Inc, Amiga Inc, Plaintiff Amiga Inc, Defendant Hyperion VOF. (Attachments: # 1 Proposed Order Stipulated Protective Oder) Noting Date 7/25/2008 (Kinsel, William)

Amiga Inc v. Hyperion VOF

Doc. 114

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER -1
Cause No: 07-0631-RSM

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON AT SEATTLE AMIGA, INC., a Delaware corporation, Plaintiff, v. HYPERION VOF, a Belgium corporation, Defendant. I. MOTION

No. 07-0631-RSM MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER Note on Motion Calendar: 07/25/08

COME NOW defendant/counterclaimant Hyperion VOF and Amiga, Inc. and move the Court pursuant to FRCP 26(c) to enter the attached Stipulated Protective Order. This Stipulated Protective Order relates not only to the documents that have been or will be produced by the parties hereto, but also to the documents that have been produced and will be produced by third parties such as Cairncross & Hempelman, who is subject to the Court's Order Denying Plaintiff's Motion to Quash (Dkt. #97). The proposed Stipulated Protective Order is the result of exhaustive efforts by the parties to resolve disputes over the proper handling of documents and information that the producing entity alleges may contain or be trade secrets. The Stipulated Protective Order LAW OFFICES OF WILLIAM A. KINSEL, PLLC
MARKET PLACE TOWER 2025 First Avenue, Suite 440 SEATTLE, WASHINGTON 98121 [phone]

Dockets.Justia.com

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further contains detailed procedures for resolving disputes over whether documents are properly designated "Confidential" or "Highly Confidential ­ Outside Counsel's Eyes Only." The parties and their counsel accordingly certify that they have conferred in good faith with each other on this matter, and that the entry of the proposed Stipulated Protective Order is appropriate. FRCP 26(c). II. CONCLUSION

For all of the foregoing reasons, Hyperion and Amiga, Inc., stipulate to the entry of, and ask this Court to enter the attached Stipulated Protective Order. DATED this 25th day of July, 2008. KINSEL LAW OFFICES, PLLC By: /s/ William A. Kinsel William A. Kinsel, WSBA #18077 Attorney for Defendant/Counterclaim Plaintiff Hyperion VOF William A. Kinsel, Esq. KINSEL LAW OFFICES, PLLC 2025 First Avenue, Suite 440 Seattle, WA 98121 Phone: [phone] Fax: [phone] Email: [e-mail] CABLE, LANGENBACH, KINERK & BAUER, LLP /s/ Lawrence R. Cock Lawrence R. Cock, WSBA No. 20326 Attorneys for Plaintiff/Counterclaim Defendant Amiga Lawrence R. Cock CABLE, LANGENBACH, KINERK & BAUER, LLP 1000 Second Avenue Suite 3500 Seattle, WA 98104 Telephone: [phone] Facsimile: 206-292-0494 [e-mail]
537p.doc

MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER -2
Cause No: 07-0631-RSM

LAW OFFICES OF WILLIAM A. KINSEL, PLLC
MARKET PLACE TOWER 2025 First Avenue, Suite 440 SEATTLE, WASHINGTON 98121 [phone]