UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION
September 27, 2011
JAMES BRADY, SARAH CAVANAGH, AND IVA CHIU, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
DELOITTE & TOUCHE LLP, A LIMITED LIABILITY PARTNERSHIP; AND DOES 1-10, INCLUSIVE,
The opinion of the court was delivered by: Honorable Susan Illston United States District Court Judge
STIPULATION AND [PROPOSED] ORDER TO UNSEAL DECERTIFICATION BRIEFS
Pursuant to Local Rule 7-12, Plaintiffs and Defendant Deloitte & Touche LLP ("Defendant"), through their respective counsel, submit the following stipulation and [proposed] 3 order that certain pleadings, as described below, conditionally filed with the Court under seal be unsealed.
confidential, proprietary, and other private information related to the parties, as well as
WHEREAS, in the course of the discovery Defendant has produced and disclosed Defendant's clients, designated "Confidential" or "Highly Confidential - Attorneys' Eyes Only" 8 pursuant to the parties' Stipulated Protective Order signed by the Court on March 10, 2009, and 9 filed in the above captioned action on March 11, 2009 ("Designated Produced Materials"), for 10 which Defendant believes special protection from public disclosure and from use for any purpose 11 other than prosecuting this litigation would be warranted; 12 13 and other private information related to the parties, as well as Defendant's clients, may be 14 included in or discussed in the parties' filings with respect to Defendant's Motion for Class
WHEREAS, the parties agreed and the Court ordered pursuant to the parties' stipulations 17 and proposed orders that Defendant's Memorandum or Points and Authorities in Support of 18 Decertification, Defendant's Reply in Support of Defendant's Motion for Class Decertification, 20 and Plaintiffs' Sur-Reply to Defendant's Motion for Class Decertification (collectively,
WHEREAS, the parties agreed that they would meet and confer regarding whether the 23 documents filed under seal pursuant to said stipulations and orders should remain under seal; and 24 25 the Decertification Briefs filed under seal to be unsealed, without prejudice to either parties' 26 rights to maintain or not maintain under seal any other briefs or documents filed with the Court 27 under seal and that said order shall not affect the under-seal status of any other briefs or 28
WHEREAS, the parties have agreed that material designated as confidential, proprietary, Decertification ("Designated Motion Materials"); Motion for Decertification, Plaintiffs' Opposition to Defendant's Motion for Class 19 "Decertification Briefs") be conditionally filed under seal;
WHEREAS, the parties, having met and conferred, have agreed that the Court may order documents filed with the Court under seal, including without limitation any exhibits referred to in 2 the Decertification Briefs.
NOW THEREFORE, the parties hereby stipulate, subject to Court approval, that the following 5 briefs conditionally filed under seal herein be unsealed:
1. Memorandum of Points and Authorities in Support of Defendant's Motion for Class Decertification;
2. Plaintiffs' Opposition to Defendant's Motion for Class Decertification;
3. Reply in Support of Defendant's Motion for Class Decertification; and
4. Plaintiffs' Sur-Reply to Defendant's Motion for Decertification.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
COUNSEL FOR DEFENDANT DELOITTE & TOUCHE LLP DATE: September 26, 2011 By: __/S/ James E. Boddy Linda E. Shostak James E. Boddy, Jr. MORRISON & FOERSTER LLP COUNSEL FOR PLAINTIFFS DATE: September 26, 2011 By: _/s/ William A. Baird_ William A. Baird Daria Dub Carlson Jeffrey K. Compton MARKUN ZUSMAN & COMPTON, LLP Steven Elster LAW OFFICE OF STEVEN ELSTER
I hereby attest that I have obtained concurrence regarding the filing
of this document from
each of the signatories within the e-filed document. 5
By: _/s/ James E. Boddy_____ DATE: September 26, 2011 James E. Boddy 7 8 DATE: September 26, 2011
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