On December 28, 2009 a
Stipulation,Agreement
was filed
involving a dispute between
New Stream Real Estate Llc (Formerly Known As Charter Oak Real Estate,
and
Charnquist, James,
Hendricks, David,
Morgan, Fred,
for ENFORCE FOREIGN JUDGMENT
in the District Court of Harris County.
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CAUSE NO. 2009-81721
NEW STREAM REAL,
ESTATE, LLC, formerly known as
CHARTER OAK REAL ESTATE
FUND, LLC.
IN THE DISTRICT COURT OF
V. HARRIS COUNTY, TEXAS
FRED MORGAN,
DAVID HENDRICKS, AND
JAMES CHARNQUIST.
MW OU UD UP UD
190™ ~JUDICIAL DISTRICT
AGREED MOTION TO ENTER CONFIDENTIALITY AND PROTECTIVE ORDER
Plaintiff New Stream Real Estate, LLC (“Plaintiff’) and Defendant Fred Morgan
(“Defendant”) file this Agreed Motion to Enter Confidentiality and Protective Order and
respectfully state as follows:
It is expected that during post-judgment discovery and/or settlement communications, the
parties or third parties will potentially discuss and/or produce confidential information.
Accordingly, to protect such confidential information from being disclosed to the public
and otherwise protect it, Plaintiff and Defendant requests the Court to enter the proposed Agreed
Confidentiality and Protective Order that is being submitted concurrently with the filing of this
we Ch Le,
Aiu.khihr avarbe
Mr. Chris Di Ferrante
402 East 11th Street
Houston, Texas 77008
713-868-1919; 713-8684 899 (Fax)
chris@cdflaw.com
ATTORNEY FOR PLAINTIFF
motion.
6485109 v1 (79561.00009.000)CERTIFICATE OF CONFERENCE
Fred Morgan agrees to this Motion.
__/s/ Chris Di Ferrante
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy hereof has been served on this 1 day of
October, 2018, as follows:
E. F. Mano DeAyala BY E-MAIL: deayala@buckkeenan.com
2229 San Felipe, Suite 1000
Houston, Texas 77019
Fred Morgan BY CERTIFIED MAIL
4801 Woodway, Suite 306-W
Houston, Texas 77056
James Charnquist BY CERTIFIED AND REGULAR MAIL
2717 Ocean Drive
Corpus Christi, TX 78404-1741
_/s/ Chris Di Ferrante__
6485109 v1 (79561.00009.000)
Document Filed Date
October 01, 2018
Case Filing Date
December 28, 2009
Category
ENFORCE FOREIGN JUDGMENT
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CAUSE NO. 2009-81721 NEW STREAM REAL, ESTATE, LLC, formerly known as CHARTER OAK REAL ESTATE FUND, LLC. IN THE DISTRICT COURT OF V. HARRIS COUNTY, TEXAS FRED MORGAN, DAVID HENDRICKS, AND JAMES CHARNQUIST. MW OU UD UP UD 190™ ~JUDICIAL DISTRICT AGREED MOTION TO ENTER CONFIDENTIALITY AND PROTECTIVE ORDER Plaintiff New Stream Real Estate, LLC (“Plaintiff’) and Defendant Fred Morgan (“Defendant”) file this Agreed Motion to Enter Confidentiality and Protective Order and respectfully state as follows: It is expected that during post-judgment discovery and/or settlement communications, the parties or third parties will potentially discuss and/or produce confidential information. Accordingly, to protect such confidential information from being disclosed to the public and otherwise protect it, Plaintiff and Defendant requests the Court to enter the proposed Agreed Confidentiality and Protective Order that is being submitted concurrently with the filing of this we Ch Le, Aiu.khihr avarbe Mr. Chris Di Ferrante 402 East 11th Street Houston, Texas 77008 713-868-1919; 713-8684 899 (Fax) chris@cdflaw.com ATTORNEY FOR PLAINTIFF motion. 6485109 v1 (79561.00009.000)CERTIFICATE OF CONFERENCE Fred Morgan agrees to this Motion. __/s/ Chris Di Ferrante CERTIFICATE OF SERVICE I hereby certify that a true and correct copy hereof has been served on this 1 day of October, 2018, as follows: E. F. Mano DeAyala BY E-MAIL: deayala@buckkeenan.com 2229 San Felipe, Suite 1000 Houston, Texas 77019 Fred Morgan BY CERTIFIED MAIL 4801 Woodway, Suite 306-W Houston, Texas 77056 James Charnquist BY CERTIFIED AND REGULAR MAIL 2717 Ocean Drive Corpus Christi, TX 78404-1741 _/s/ Chris Di Ferrante__ 6485109 v1 (79561.00009.000)