On March 14, 2017 a
Stipulation,Agreement
was filed
involving a dispute between
Jordan, Justin,
and
Arkema Inc,
Evoqua Water Technologies,
Luna Engineering And Design Inc,
Vapor Technologies Inc,
Vopak Americas,
Vopak North America Inc,
Vopak Terminal Deer Park Inc,
for PERSONAL INJ (NON-AUTO)
in the District Court of Harris County.
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JUSTIN JORDAN, IN THE DISTRICT COURT
VS. OF HARRIS COUNTY, T E X A S
VOPAK TERMINAL DEER PARK INC.
AND VOPAK NORTH AMERICA INC.
(d/b/a VOPAK AMERICAS),
129TH JUDICIAL DISTRICT
JOINT MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER
The Parties jointly request that the Court enter the proposed Agreed Amended Protective
Order attached here
certain documents and other
information that may be discoverable in this case.
Good cause exists for the entry of the proposed order. The Parties agree that
discovery in this case may i
documents and information. Some of this confidential information may pertain to non-parties.
Discovery may pose an issue for the Partie
inasmuch as this case may involve sensitive, proprietary, and confidenti
information, including information covering the business, financial condition, operations, assets,
nd non-parties, among others.
Counsel Defendants Vopak Terminal Deer Park Inc. and Vopak North America
Inc. for as well as counsel for Plaintiff Justin Jordan have agreed on the form and substance of
Agreed Protective
Order attached hereto
Respectfully submitted,
RACEWELL
/s/ William A. Moss
State Bar No. 24050519
William A. Moss
Email: chris.dodson@bracewell.com
Email: will.moss@bracewell.com
ERMINAL DEER PARK INC. AND
VOPAK NORTH AMERICA INC.
ILLIAMS
/s/ Jim Cole
Jim Cole
State Bar No. 04538500
302 West Forest Street
Facsimile: (361) 575-0986
Email: jcole@colefirmservice.com
Y FOR PLAINTIFF JUSTIN
ERVICE
copy of the foregoing document has been
forwarded via email to all co nsel of record in accordance with the Texas Rules of
Procedure on October 1
/s/ William A. Moss
William A. Moss
Document Filed Date
October 13, 2017
Case Filing Date
March 14, 2017
Category
PERSONAL INJ (NON-AUTO)
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JUSTIN JORDAN, IN THE DISTRICT COURT VS. OF HARRIS COUNTY, T E X A S VOPAK TERMINAL DEER PARK INC. AND VOPAK NORTH AMERICA INC. (d/b/a VOPAK AMERICAS), 129TH JUDICIAL DISTRICT JOINT MOTION FOR ENTRY OF AGREED PROTECTIVE ORDER The Parties jointly request that the Court enter the proposed Agreed Amended Protective Order attached here certain documents and other information that may be discoverable in this case. Good cause exists for the entry of the proposed order. The Parties agree that discovery in this case may i documents and information. Some of this confidential information may pertain to non-parties. Discovery may pose an issue for the Partie inasmuch as this case may involve sensitive, proprietary, and confidenti information, including information covering the business, financial condition, operations, assets, nd non-parties, among others. Counsel Defendants Vopak Terminal Deer Park Inc. and Vopak North America Inc. for as well as counsel for Plaintiff Justin Jordan have agreed on the form and substance of Agreed Protective Order attached hereto Respectfully submitted, RACEWELL /s/ William A. Moss State Bar No. 24050519 William A. Moss Email: chris.dodson@bracewell.com Email: will.moss@bracewell.com ERMINAL DEER PARK INC. AND VOPAK NORTH AMERICA INC. ILLIAMS /s/ Jim Cole Jim Cole State Bar No. 04538500 302 West Forest Street Facsimile: (361) 575-0986 Email: jcole@colefirmservice.com Y FOR PLAINTIFF JUSTIN ERVICE copy of the foregoing document has been forwarded via email to all co nsel of record in accordance with the Texas Rules of Procedure on October 1 /s/ William A. Moss William A. Moss