Central District Consumer Bankruptcy Attorney's Association

Since you're open to feedback, I would say that I don't understand what is
trying to be accomplished. A corporation does not want to produce without
an order. I assume by order you mean a protective order and not an order
granting a motion to compel.
So what is going to be protected here? Are you looking to produce ESI but
want to have protections for privileged documents regardless of your lack
of due diligence in checking the documents before they are produced or is
there something I am missing? You're also going to need a stipulation or
motion of some kind to go along with it correct, or how will you get the
judge to sign this order?
Sincerely,
*Michael Avanesian, Esq. *AVANESIAN LAW FIRM
101 N. Brand Blvd., PH 1920
Glendale, California 91203
Tel: 818.276.2477 Fax: 818.208.4550
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On Wed, Feb 18, 2015 at 6:14 PM, Bert Briones bertbri@ymail.com [cdcbaa] wrote:
>
>
> Does anyone have a sample of a protective order. If you are willing to
> share one please send to me offline at bb@redhilllawgroup.com.
>
> I have a 2004 Examination where a corporate entity does not want to
> provide documentation without out an order. The exam is being conducted by
> Creditor A who has made an agreement with the corporation that they will
> agree to a protective order. I represent the debtor-in-possession who is a
> minority shareholder of the corporation.
>
> Thanks for any feedback and/or a sample....Bert
>
>
>
Since you're open to feedback, I would say that I don't understand what is trying to be accomplished. A corporation does not want to produce without an order. I assume by order you mean a protective order and not an order granting a motion to compel.So what is going to be protected here? Are you looking to produce ESI but want to have protections for privileged documents regardless of your lack of due diligence in checking the documents before they are produced or is there something I am missing? You're also going to need a stipulation or motion of some kind to go along with it correct, or how will you get the judge to sign this order?Sincerely,Michael Avanesian, Esq.AVANESIAN
LAW FIRM101
N. Brand Blvd., PH 1920Glendale,
California 91203Tel:
818.276.2477 Fax: 818.208.4550Confidentiality:This electronic transmission and its contents are legally privileged and confidential information and intended solely for the use of the addressee. If the reader of this message is not the intended recipient, you are hereby notified that any dissemination, distribution, copying or other use of this message and its contents is strictly prohibited. If you have received this transmission in error, please reply to us immediately and delete this message from your directory.IRS Circular 230 Disclosure:To ensure compliance with requirements imposed by the IRS, please be advised that any U.S. federal tax advice contained in this communication (including any attachments) is not intended or written to be used or relied upon, and cannot be used or relied upon, for the purpose of (i) avoiding penalties under the Internal Revenue Code, or (ii) promoting, marketing or recommending to another party any transaction or matter addressed herein.
On Wed, Feb 18, 2015 at 6:14 PM, Bert Briones bertbri@ymail.com [cdcbaa] <cdcbaa@yahoogroups.com> wrote:

The post was migrated from Yahoo.

Does anyone have a sample of a protective order. If you are willing to share one please send to me offline at bb@redhilllawgroup.com.
I have a 2004 Examination where a corporate entity does not want to provide documentation without out an order. The exam is being conducted by Creditor A who has made an agreement with the corporation that they will agree to a protective order. I represent the debtor-in-possession who is a minority shareholder of the corporation.
Thanks for any feedback and/or a sample....Bert

The post was migrated from Yahoo.