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Include the following notice if a minor is named in the caption or if the motion contains other unredacted sensitive data. See § 6 of the Introduction in volume 1 of this manual concerning protection of sensitive data in filed documents. |
NOTICE: THIS DOCUMENT
CONTAINS SENSITIVE DATA
[Caption. See § 3 of the Introduction in volume 1 of this manual.]
[Joint] Motion for ADR Protective Order
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Use the following if the motion is a joint motion. |
This Joint Motion for an ADR Protective Order is brought by attorney[s] for Petitioner, [name of petitioner], attorney[s] for Respondent, [name of respondent], and [name], who has been appointed by the Court as [arbitrator/mediator]. In support, Movants show the following:
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Use the following if the motion is not a joint motion. |
This Motion for an ADR Protective Order is brought by Movant, [name of movant]. In support, Movant shows the following:
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Continue with the following. |
1.This case has been set for [an arbitration/a mediation] to begin on [date] at [time], to continue until approximately [date] at [time], and to take place at [location].
2.Movant has been appointed as the [mediator/arbitrator] in this case.
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Or |
2.Movant is an advocate representing [Petitioner/Respondent] in this case in the ADR procedure.
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Or |
2.Movants are participants in the ADR procedure.
3.Movant[s] [is/are][an] attorney[s] whose practice is primarily in [county] County, Texas.
4.In the interest of justice, Movant[s] seek[s] this ADR Protective Order to allow Movant[s] to participate in the ADR procedure at the designated time and place and to prevent undue burden, unnecessary expense, duplication of preparation time, harassment, or annoyance of Movant[s] and the other participants in the ADR procedure and to allow the ADR procedure to take place without interruption.
5.Movant[s] request[s] an ADR Protective Order.
6.Movant[s] pray[s] that the Court grant the relief requested above and for general relief.
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Use the following signature blocks if motion is a joint motion. |
[Name]
Attorney for Petitioner
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
[Name]
Attorney for Respondent
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
[Name]
Court-Appointed [Mediator/Arbitrator]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
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Use the following signature block and certificate of service if the motion is not a joint motion. |
[Name]
[Attorney for [Petitioner/Respondent]/ Court-Appointed [Mediator/Arbitrator]]
State Bar No.:
[E-mail address]
[Address]
[Telephone]
[Fax]
Certificate of Service
I certify that a true copy of this [document/[title of document]] was served in accordance with rule 21a of the Texas Rules of Civil Procedure on the following on [date]:
[Name of attorney of record or party to be served] by [electronic filing manager/e-mail at [e-mail address]/fax at [fax number]/personal delivery at [address]/commercial delivery service at [address]/certified mail at [address]/first-class mail at [address]]. [Repeat for each attorney of record or party to be served.]
[Name]
Attorney for [name]