The opinion of the court was delivered by: Judge: Honorable Joseph C. Spero
CLASS ACTION STIPULATION TO FILE ATTORNEY BILLING INVOICES UNDER SEAL
Time: 9:30 a.m. Crtrm.: G
WHEREAS, Local Rules 7-11 and 79-5 require a written stipulation between the parties to support an administrative motion to file any document under seal.
WHEREAS, Plaintiff Albert Alatorre intends to file attorney billing records of Wasserman, Comden, Casselman & Esensten, L.L.P. ("WCCE") and Keller Grover LLP ("KG") (collectively, "Class Counsel") in support of his Motion for Attorneys' Fees and Costs and Incentive Award Payment.
WHEREAS, Class Counsel has represented to counsel for Defendant 24 Hour Fitness USA, Inc. ("24 Hour") that Class Counsel's attorney billing invoices for this litigation reflect privileged attorney-client communications and/or protected attorney work product.
NOW THEREFORE, IT IS HEREBY STIPULATED, pursuant to Local Rules 7-11, 7-12, and 79-5, by and between the parties to this case through their respective attorneys of record that:
AN & ESENSTEN, L.L.P. In support of Plaintiff's Motion for Attorneys' Fees and Costs and Incentive Award Payment and subject to Court approval, Plaintiff shall be permitted to file Class Counsel's attorney 5567 RESEDA BOULEVARD, SUITE 330 TARZANA, CALIFORNIA 91357-7033 billing invoices for this litigation under seal for the Court's in camera review and inspection. WASSERMAN, COMDEN, CASSELM POST OFFICE BOX 7033
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
DATED: January 13, 2012 WASSERMAN, COMDEN, CASSELMAN & ESENSTEN, L.L.P. By: /s/-Melissa Meeker Harnett MELISSA MEEKER HARNETT Attorneys for Plaintiff Albert Alatorre and the Class DATED: January 13, 2012 KELLER GROVER L.L.P. By: /s/-Jeffrey F. Keller JEFFREY F. KELLER 24 Attorneys for Plaintiff Albert Alatorre and the Class DATED: January 13, 2012 KIRKLAND & ELLIS LLP By: /s/-Adam W. Holbrook Elizabeth L. Deeley 4 Nickolas A. Kacprowski Adam W. Holbrook 5 Attorneys for Defendant 24 Hour Fitness USA, Inc.
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