Document for Steven Smith v. Richard Halt, Fedex Ground Package System, Inc., Riteway Delivery, Inc.

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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.



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       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




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