On September 09, 2008 a
DEFN JANE & ROBERT OLIVER MOT/QUASH SUBPS DT & FOR
was filed
involving a dispute between
and
for OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
in the District Court of Tarrant County.
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CAUSE NO. 153-232668-08
VIRGINIA 0. KINSEL, ET AL. § IN THE DISTRICT COURT OF
§
v. § TARRANT COUNTY, TEXAS
§
JANE 0. LINDSEY, ET AL. § 153rd JUDICIAL DISTROOT r-:o
";.1:. ::::
0 ,_;>
DEFENDANTS JANE 0. LINDSEY'S AND ROBERT r£?;. ~
OLIVER'S MOTION TO QUASH SUBPOENAS ~ c.n -;:
DUCES TECUM AND FOR PROTECTIVE ORDER ~?-· -o
14 ::]:
f"T'\ .......
~p .r:.
TO THE HONORABLE JUDGE OF SAID COURT: C) cJ'\
rn o
::0
NOW COME Defendants Jane 0. Lindsey, Individually and in her
capacity as co-trustee of the Lesey B. Kinsel Trust, and Robert N. Oliver and,
in support of this Motion to Quash Subpoenas Duces Tecum andfor Protective
Order, would respectfully show the Court as follows:
I.
SUMMARY OF RELIEF REOUESTED
On December 11, 2012, Plaintiffs issued and served subpoenas duces
tecum directed to Movants and their attorneys to appear at a hearing, provide
testimony, and produce documents that are protected by the attorney-client and
work-product privileges. The subpoenas should be quashed and Movants and
their attorneys should not be required to provide testimony or produce the
DEFENDANTS' MOTION TO QUASH SUBPOENA DUCES TECUM AND
FOR PROTECTIVE ORDER Page 1
G:\lari-•\JULIA\FIU:S\UNDSEV •"'· KlNSEL\f'LEAUINGS'JANE AND BOB'S MOTION TO QUASII AND FOR PROTECTIVE OROER.•p4
documents identified therein. The issues upon which Plaintiffs seek testimony
are premature and the documents they seek are privileged and irrelevant to any
issue in this case.
II.
DOCUMENTS REQUESTED
The subpoena to Jane 0. Lindsey, individually, seeks:
All billing records, billing statements, copies of checks, records of
payments, and invoices to any of the following: (1) Jane 0.
Lindsey, individually; and (2) Robert Oliver, individually, by Keith
Branyon, Jackson, Walker, L.L.P ., and Bourland & Kirkman, L.L.P.
during the period beginning February 1, 2007 and extending
through and including the date of the above referenced hearing.
The subpoena to Jane 0. Lindsey in her capacity as trustee seeks:
All billing records, billing statements, copies of checks, records of
payments, and/or invoices to any of the following: (1) Jane Lindsey
as Trustee ofthe Lesey B. Kinsel Trust; (2) The Lesey B. Kinsel
Trust; (3) Lesey B. Kinsel; (4) Jane Lindsey, individually; and (5)
Robert Oliver, individually by Keith Branyon, Jackson Walker,
L.L.P ., and Bourland & Kirkman, L.L.P ., during the period
beginning February 1, 2007 and extending through and including
the date of the above referenced hearing.
The subpoena to William L. Kirkman seeks:
All billing records, billing statements, invoices for fees and
expenses, time slips, records of payments, and invoices to any ofthe
following: (1) The Lesey B. Kinsel Trust; (2) Jane 0. Lindsey as
Trustee, of the Lesey B. Kinsel Trust; (3) Jane 0. Lindsey
DEFENDANTS' MOTION TO QUASH SUBPOENA DUCES TECUM AND
FOR PROTECTIVE ORDER Page 2
G:\Klr ..... n\JULIA\flLES\LINDSEV ... ¥. KI."
Document Filed Date
December 14, 2012
Case Filing Date
September 09, 2008
Category
OTHER CIVIL, TEMP RESTRAINING ORDER/INJUNCTION
Status
DISMISSED OR NON-SUITED
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CAUSE NO. 153-232668-08 VIRGINIA 0. KINSEL, ET AL. § IN THE DISTRICT COURT OF § v. § TARRANT COUNTY, TEXAS § JANE 0. LINDSEY, ET AL. § 153rd JUDICIAL DISTROOT r-:o ";.1:. :::: 0 ,_;> DEFENDANTS JANE 0. LINDSEY'S AND ROBERT r£?;. ~ OLIVER'S MOTION TO QUASH SUBPOENAS ~ c.n -;: DUCES TECUM AND FOR PROTECTIVE ORDER ~?-· -o 14 ::]: f"T'\ ....... ~p .r:. TO THE HONORABLE JUDGE OF SAID COURT: C) cJ'\ rn o ::0 NOW COME Defendants Jane 0. Lindsey, Individually and in her capacity as co-trustee of the Lesey B. Kinsel Trust, and Robert N. Oliver and, in support of this Motion to Quash Subpoenas Duces Tecum andfor Protective Order, would respectfully show the Court as follows: I. SUMMARY OF RELIEF REOUESTED On December 11, 2012, Plaintiffs issued and served subpoenas duces tecum directed to Movants and their attorneys to appear at a hearing, provide testimony, and produce documents that are protected by the attorney-client and work-product privileges. The subpoenas should be quashed and Movants and their attorneys should not be required to provide testimony or produce the DEFENDANTS' MOTION TO QUASH SUBPOENA DUCES TECUM AND FOR PROTECTIVE ORDER Page 1 G:\lari-•\JULIA\FIU:S\UNDSEV •"'· KlNSEL\f'LEAUINGS'JANE AND BOB'S MOTION TO QUASII AND FOR PROTECTIVE OROER.•p4 documents identified therein. The issues upon which Plaintiffs seek testimony are premature and the documents they seek are privileged and irrelevant to any issue in this case. II. DOCUMENTS REQUESTED The subpoena to Jane 0. Lindsey, individually, seeks: All billing records, billing statements, copies of checks, records of payments, and invoices to any of the following: (1) Jane 0. Lindsey, individually; and (2) Robert Oliver, individually, by Keith Branyon, Jackson, Walker, L.L.P ., and Bourland & Kirkman, L.L.P. during the period beginning February 1, 2007 and extending through and including the date of the above referenced hearing. The subpoena to Jane 0. Lindsey in her capacity as trustee seeks: All billing records, billing statements, copies of checks, records of payments, and/or invoices to any of the following: (1) Jane Lindsey as Trustee ofthe Lesey B. Kinsel Trust; (2) The Lesey B. Kinsel Trust; (3) Lesey B. Kinsel; (4) Jane Lindsey, individually; and (5) Robert Oliver, individually by Keith Branyon, Jackson Walker, L.L.P ., and Bourland & Kirkman, L.L.P ., during the period beginning February 1, 2007 and extending through and including the date of the above referenced hearing. The subpoena to William L. Kirkman seeks: All billing records, billing statements, invoices for fees and expenses, time slips, records of payments, and invoices to any ofthe following: (1) The Lesey B. Kinsel Trust; (2) Jane 0. Lindsey as Trustee, of the Lesey B. Kinsel Trust; (3) Jane 0. Lindsey DEFENDANTS' MOTION TO QUASH SUBPOENA DUCES TECUM AND FOR PROTECTIVE ORDER Page 2 G:\Klr ..... n\JULIA\flLES\LINDSEV ... ¥. KI."