Case 5:08-cv-02011-SMH-MLH Document 132. F 4/10 Page 1 of 2 PagelD #: 2690 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA SHREVEPORT DIVISION U.L. COLEMAN COMPANY, LTD, CIVIL ACTION NO.: 08-2011 SEQUOIA VENTURE NO. 2, LTD, AND A. ‘TEAGUE PARKWAY, LLC v. JUDGE S. MAURICE HICKS, JR. BOSSIER CITY-PARISH METROPOLITAN MAGISTRATE JUDGE HORNSBY PLANNING COMMISSION, OFFICE OF PERMITS AND INSPECTIONS FOR THE CITY OF BOSSIER, AND THE CITY COUNSEL OF BOSSIER CITY [AS DIRECTED. TO NON PARTIES NOW INTO COURT, through their undersigned counsel, come BROWN BUILDERS, INC., DOUG BROWN and WAYNE BROWN, who move the court pursuant to Federal Rule of Civil Procedure 45 to quash subpoenas issued by U.L. Coleman Co., Lid., Sequoia Venture No. 2, Ltd., and A. Teague Parkway, L:L.C. Pursuant to Rule 45 of the Federal Rules of Civil Procedure, movants show that they are third parties, with no interest in this litigation and that the subpoenas should be quashed in that (the information sought imposes an undue burden, secking information, having no apparent relevance to any of the allegations in the lawsuit, extending over a period of eight years of time, involving hundreds of files, including many which may have LeCase 5:08-ev-02011-SMH-MLH Document 132 Filed 12/14/10 Page 2 of 2 PagelD #: 2691 been placed in storage, lost or misplaced Gi) the subpoenas fail to allow reasonable time for compliance, and (iii) seek the disclosure of confidential, proprietary commercial information from movants to parties who may be in competition with movants in the Shreveport/Bossier metropolitan area. Movants certify that through their counsel, promptly upon receipt of the subpoenas, they contacted James McMichsel, counsel for U.L, Coleman Company, Ltd., seeking relief from the subpoena and a narrowing of the information sought therein, together with the issuance of a Protective Order. Mr. McMichael indicated that this request would be forwarded to his co-counsel, Adams and Reese, LLP. No further response has been received from counsel for U.L. Coleman Company, Ltd. Respectfully submiséA, HARPER LAW FI JERALD R'HARPER La, Bar Roll No. 6585 213 exe Street ‘Shreveport, Louisiana 71101 (318) 213-8800 (lelephone) (318) 213-8804 (facsimile) Harper@harperfirm.com (Email) ATTORNEY FOR BROWN BUILDERS, INC., DOUG BROWN and WAYNE BROWN