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  • Steven Smith v. Richard Halt, Fedex Ground Package System, Inc., Riteway Delivery, Inc.CT - Civil Tort document preview
  • Steven Smith v. Richard Halt, Fedex Ground Package System, Inc., Riteway Delivery, Inc.CT - Civil Tort document preview
  • Steven Smith v. Richard Halt, Fedex Ground Package System, Inc., Riteway Delivery, Inc.CT - Civil Tort document preview
  • Steven Smith v. Richard Halt, Fedex Ground Package System, Inc., Riteway Delivery, Inc.CT - Civil Tort document preview
						
                                

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Filed: 9/20/2023 9:21 AM Judge, Circuit Court Grant County, Indiana 104827.99 STATE OF INDIANA IN THE GRANT CIRCUIT COURT COUNTY OF GRANT CAUSE NO.: 27C01-2307-CT-000053 STEVEN SMITH, Plaintiff, v. RICHARD HALT, RITEWAY DELIVERY, INC., and FEDEX GROUND PACKAGE SYSTEM, INC., Defendants. MOTION FOR STIPULATION OF CONFIDENTIALITY AND PROTECTIVE ORDER COME NOW, Defendants, Richard Halt, Riteway Delivery, Inc., and FedEx Ground Package System, Inc., by counsel Edward C. Harcourt of Kopka Pinkus Dolin PC, and pursuant to the Indiana Rules of Civil Procedure, Rule 26(c), move the court to approve the Stipulation of Confidentiality and Protective Order filed contemporaneously herewith. In support of this Motion, Defendants state as follow: 1. There is “good cause” to grant this Motion. 2. The parties hereto have been and may be requested to produce or disclose through discovery certain materials and information which they maintain is, or contains, trade secret, proprietary information, confidential commercial information, financial and/or personal information, and/or other confidential information. 3. The entry of the Stipulation of Confidentiality and Protective Order will facilitate the production of document discovery between the parties. 4. Counsel for Plaintiff does not object to the proposed Stipulation of Confidentiality and Protective Order, and has executed the same along with counsel for Defendants. 1 WHEREFORE, Defendants respectfully request that the Court approve and sign the proposed Stipulation of Confidentiality and Protective Order thereby entering it in this cause, and for all other relief deemed appropriate by the Court. Respectfully Submitted, KOPKA PINKUS DOLIN PC By: /s/Edward C. Harcourt Edward C. Harcourt (#32360-49) Attorney for Defendants CERTIFICATE OF SERVICE I hereby certify that on the 20th day of September, 2023, I electronically filed the foregoing document using the Indiana E-Filing System (IEFS). I further certify that the following persons were served on the same date using the IEFS: Whitney K. Beck The Beck Law Office 401 W. Walnut St. P. O. Box 868 Kokomo, IN 46903-0868 /s/ Edward C. Harcourt KOPKA PINKUS DOLIN PC 11711 N. Meridian, Suite 350 Carmel, IN 46032 Tel: (317) 814-8098 Fax: (317) 818-1390 Email: ECHarcourt@kopkalaw.com 2