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James Brady, Sarah Cavanagh, and Iva Chiu v. Deloitte & Touche Llp

October 27, 2011

JAMES BRADY, SARAH CAVANAGH, AND IVA CHIU, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
DELOITTE & TOUCHE LLP, A LIMITED LIABILITY PARTNERSHIP; AND DOES 1-10, INCLUSIVE,
DEFENDANTS



The opinion of the court was delivered by: Honorable Susan Illston United States District Court Judge

STIPULATION AND [PROPOSED] ORDER TO UNSEAL SOLIS 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 4 unsealed. 5

6 confidential, proprietary, and other private information related to the parties, as well as 7

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 15

WHEREAS, the parties agreed and the Court ordered pursuant to the parties' stipulations 17 and proposed orders that Plaintiffs' Briefing re Solis v. Washington and Plaintiffs' Reply to 18 Deloitte's Briefing re Solis v. Washington (collectively, "Solis Briefs") be conditionally filed 19 under seal; 20 21 documents filed under seal pursuant to said stipulations and orders should remain under seal; and 22

WHEREAS, the parties, having met and conferred, have agreed that the Court may order 23 the Solis Briefs filed under seal to be unsealed, without prejudice to either parties' rights to 24 maintain or not maintain under seal any other briefs or documents filed with the Court under seal 25 and that said order shall not affect the under-seal status of any other briefs or documents filed 26 with the Court under seal, including without limitation any exhibits referred to in the Solis Briefs. 27

WHEREAS, the parties have agreed that material designated as confidential, proprietary, Decertification ("Designated Motion Materials"); 16

WHEREAS, the parties agreed that they would meet and confer regarding whether the following briefs conditionally filed under seal herein be unsealed:

NOW THEREFORE, the parties hereby stipulate, subject to Court approval, that the

1. Plaintiffs' Briefing re Solis v. Washington; and

2. Plaintiffs' Reply to Deloitte's Briefing re Solis ...


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