On August 16, 2018 a
Motion re: - MOTION RE: ENTRY OF CONFIDENTIALITY AND PROTECTIVE ORDER
was filed
involving a dispute between
Martinez William,
Uncle Junk'S Genius Juice Llc,
and
Lg Chem Ltd,
Mrl Distributor Llc Dba Mech Energy Source,
Uncle Junk'S Genius Juice Llc,
Vape Citi Inc,
for civil
in the District Court of Los Angeles County.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/10/2019 03:30 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Cappadona,Deputy Clerk
LEWIS BRISBOIS BISGAARD & SMITH LP
TREVOR J. INGOLD, SB# 193227
E-Mail: Trevor.Ingold@lewisbrisbois.com
JAMES: BROOKS, SB# 256381
E-Mail: James.Brooks@lewisbrisbois.com
633 West 5" Street, Suite 4000
Los Angeles, California‘90071
Telephone: 2 .250.1800
5 Facsimile: 2 -250.7900
Attorneys for Specially Appearing Defendant
LG CHEM, LTD.
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF LOS ANGELES, SOUTHEAST DISTRICT
10 WILLIAM MARTINEZ an individual, CASE NO, BC718612
11 Plaintiff, SPECIALLY APPEARING DEFENDANT
LG CHEM, LTD.’S MOTION FOR
12 VS. ENTRY OF CONFIDENTIALITY AND
PROTECTIVE ORDER; SUPPORTING
13 LG CHEM,.LTD., a Korean corporation; DECLARATION OF JAMES BROOKS,
UNCLE JUNK’S GENIUS JUICE, LLC, a ESQ.
14 California limited liability company; VAPE
CITL, INC., a California corporation; and Date: September 10, 2019
15 DOES 1-100 inclusive, and each of them; Time: 1:30 pm.
Dept: Cc
16 Defendants.
[Assigned to Hon. Margaret Miller Bernal,
17 Dept. F]
18 Action Filed: August 16, 2018
Trial Date: None Set
19
20 TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD:
21 PLEASE TAKE NOTICE THAT on September 10, 2019 at 1:30 p.m. in Department C of.
22 the above-referenced Court, Specially Appearing Defendant LG Chem, Ltd. (“LG Chem”) will
23 move.the Court for entry of a Confidentiality Protective Order, in the form attached as Exhibit A,
24 to establish the protocol by which the parties may designate materials Confidential.
25 LG Chem brings this Motion because’ the parties are unable to agree on a confidentiality
26 protocol. The parties are-currently engaged in jurisdictional discovery, and Plaintiff has sought
27 production of LG Chem’s confidential information. Previously, Plaintiff's. counsel and LG
28 Chem’s counsel agreed to. a-confidentiality protocol in another case involving similar allegations
LEWIS
BRISBOIS
BISGAARD SPECIALLY APPEARING DEFENDANT LG.CHEM, LTD.’S MOTION FOR ENTRY OF CONFIDENTIALITY
& SMATH LLP
ICI Ara AND PROTECTIVE ORDER,
Document Filed Date
July 10, 2019
Case Filing Date
August 16, 2018
Status
Court-Ordered Dismissal - Other (Other) 10/22/2020
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
Electronically FILED by Superior Court of California, County of Los Angeles on 07/10/2019 03:30 PM Sherri R. Carter, Executive Officer/Clerk of Court, by C. Cappadona,Deputy Clerk LEWIS BRISBOIS BISGAARD & SMITH LP TREVOR J. INGOLD, SB# 193227 E-Mail: Trevor.Ingold@lewisbrisbois.com JAMES: BROOKS, SB# 256381 E-Mail: James.Brooks@lewisbrisbois.com 633 West 5" Street, Suite 4000 Los Angeles, California‘90071 Telephone: 2 .250.1800 5 Facsimile: 2 -250.7900 Attorneys for Specially Appearing Defendant LG CHEM, LTD. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF LOS ANGELES, SOUTHEAST DISTRICT 10 WILLIAM MARTINEZ an individual, CASE NO, BC718612 11 Plaintiff, SPECIALLY APPEARING DEFENDANT LG CHEM, LTD.’S MOTION FOR 12 VS. ENTRY OF CONFIDENTIALITY AND PROTECTIVE ORDER; SUPPORTING 13 LG CHEM,.LTD., a Korean corporation; DECLARATION OF JAMES BROOKS, UNCLE JUNK’S GENIUS JUICE, LLC, a ESQ. 14 California limited liability company; VAPE CITL, INC., a California corporation; and Date: September 10, 2019 15 DOES 1-100 inclusive, and each of them; Time: 1:30 pm. Dept: Cc 16 Defendants. [Assigned to Hon. Margaret Miller Bernal, 17 Dept. F] 18 Action Filed: August 16, 2018 Trial Date: None Set 19 20 TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD: 21 PLEASE TAKE NOTICE THAT on September 10, 2019 at 1:30 p.m. in Department C of. 22 the above-referenced Court, Specially Appearing Defendant LG Chem, Ltd. (“LG Chem”) will 23 move.the Court for entry of a Confidentiality Protective Order, in the form attached as Exhibit A, 24 to establish the protocol by which the parties may designate materials Confidential. 25 LG Chem brings this Motion because’ the parties are unable to agree on a confidentiality 26 protocol. The parties are-currently engaged in jurisdictional discovery, and Plaintiff has sought 27 production of LG Chem’s confidential information. Previously, Plaintiff's. counsel and LG 28 Chem’s counsel agreed to. a-confidentiality protocol in another case involving similar allegations LEWIS BRISBOIS BISGAARD SPECIALLY APPEARING DEFENDANT LG.CHEM, LTD.’S MOTION FOR ENTRY OF CONFIDENTIALITY & SMATH LLP ICI Ara AND PROTECTIVE ORDER,