Quinlan et al v. General Dynamics Mission Systems, Inc. et al

Joint MOTION Seeking Entry of a Protective Order

E.D. Tex.September 19, 2017

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION DEBORAH QUINLAN AND MICHAEL EMBREY, Plaintiffs, v. GENERAL DYNAMICS MISSION SYSTEMS, INC. AND GENERAL DYNAMICS C4 SYSTEMS, INC., Defendants. § § § § § § § § § § § § Civil Action No. 2:17-cv-00529 JURY TRIAL DEMANDED JOINT MOTION SEEKING ENTRY OF A PROTECTIVE ORDER Plaintiff Deborah Quinlan and Plaintiff Michael Embrey (collectively, “Plaintiffs”), Defendant General Dynamics Mission Systems, Inc. and Defendant General Dynamics C4 Systems, Inc.1 (collectively, “Defendants”), hereafter referred to as the “Parties,” file this Joint Motion Seeking Entry of a Protective Order. The Parties have conferred and have agreed to all terms of a proposed Protective Order. Accordingly, the Parties hereby submit the attached agreed upon proposed Protective Order and respectfully request the Court enter the same. Dated: September 19, 2017 Respectfully submitted, Eric M. Albritton Texas State Bar No. 00790215 /s/ Gary D. Eisenstat Gary D. Eisenstat Texas State Bar No. 06503200 1 Defendants state that on January 1, 2016, General Dynamics C4 Systems, Inc. merged with another entity, and the combined entity became General Dynamics Mission Systems, Inc. As a result, General Dynamics C4 Systems, Inc. no longer exists as a legal entity. Case 2:17-cv-00529-JRG Document 16 Filed 09/19/17 Page 1 of 2 PageID #: 105 2 ema@emafirm.com Shawn A. Latchford Texas State Bar No. 24066603 sal@emafirm.com ALBRITTON LAW FIRM 111 West Tyler Longview, Texas 75601 Telephone: (903) 757-8449 Facsimile: (903) 758-7397 Christie M. Merchant Texas State Bar No. 24070219 cmm@emafirm.com ALBRITTON LAW FIRM 680 North Carroll Avenue, Suite 110 Southlake, Texas 76092 Telephone: (817) 251-0610 Counsel for Plaintiffs Deborah Quinlan and Michael Embrey gary.eisenstat@ogletreedeakins.com Jeremy W. Hays Texas State Bar No. 24083156 jeremy.hays@ogletreedeakins.com OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C. 8117 Preston Road, Suite 500 Dallas, Texas 75225 Telephone: (214) 987-3800 Facsimile: (214) 987-3927 Counsel for Defendants General Dynamics Mission Systems, Inc. and General Dynamics C4 Systems, Inc. CERTIFICATE OF SERVICE The undersigned certifies that the foregoing document was filed electronically in compliance with Local Rule CV-5(a). As such, this motion was served on all counsel who are deemed to have consented to electronic service. Local Rule CV-5(a)(3)(A). Pursuant to Fed. R. Civ. P. 5(d) and Local Rule CV-5(d) and (e), all other counsel of record not deemed to have consented to electronic service were served with a true and correct copy of the foregoing by email, on this the 19th day of September, 2017. ____________________________ Eric M. Albritton Case 2:17-cv-00529-JRG Document 16 Filed 09/19/17 Page 2 of 2 PageID #: 106