UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
June 19, 2012
RONALD LEE BELL,
KEVIN CHAPPELL, WARDEN (ACTING) OF THE CALIFORNIA STATE PRISON AT SAN QUENTIN,
The opinion of the court was delivered by: Ronald M. Whyte United States District Judge
MICHAEL SATRIS KAMALA D. HARRIS 2 State Bar No. 67413 Attorney General of California MARGARET LITTLEFIELD DANE R. GILLETTE 3 State Bar No. 110938 Chief Assistant Attorney General 4 Law Offices of Michael Satris RONALD S. MATTHIAS Post Office Box 337 Senior Assistant Attorney General 5 Bolinas, Calif. 94924 State Bar No. 104684 6 Tel: (415) 868-9209 455 Golden Gate Avenue, Suite 11000 Fax: (415) 868-2658 San Francisco, CA 94102-7004 7 Email: email@example.com Telephone: (415) 703-5858 8 Fax: (415) 703-1234 Attorneys for Petitioner E-mail: Ronald.Matthias@doj.ca.gov 9 Ronald Lee Bell Attorneys for Respondent and People of the State of California, Real Party in Interest
STIPULATION OF THE PARTIES AND ORDER RE: PETITIONER'S ADMINISTRATIVE MOTION TO FILE AND MAINTAIN EXHIBIT D TO COUNSEL'S DECLARATION IN SUPPORT OF PETITIONER'S OPPOSITION TO RESPONDENT'S MOTION TO DISMISS UNDER SEAL.
Hearing Date: Fri. March 9, 2012
Time: 9:00 a.m. Respondent. Courtroom: No. 6, 4th Floor San Jose
DEATH PENALTY CASE
12, and GO 62 hereby stipulate that copies of medical records submitted as The parties, through their counsel and pursuant to local rules 79-5, 7-11, 7-
Exhibit D to the Declaration of Counsel in Support of Petitioner's Opposition to 4 the Motion to Dismiss for Failure to Prosecute, shall be filed and maintained 5 under seal.
State of California and the United States of America: 12
2. In conjunction with Petitioner's Opposition to Respondent's Motion to Dismiss for Failure to Prosecute and Failure to Comply With Court's Order, counsel for Petitioner intends to submit a declaration to which Exhibits A through D will be attached.
3. Exhibit D to counsel's declaration consists of copies of San Quentin medical records on petitioner, and I have so represented to opposing counsel.
4. Medical records are the type of document appropriately filed under seal.
DECLARATION OF COUNSEL FOR PETITIONER IN SUPPORT OF ADMINISTRATIVE MOTION AND STIPULATION TO FILE SPECIFIED DOCUMENTS UNDER SEAL
I, Margaret Littlefield, declare under penalty of perjury of the laws of the
1. I am an attorney appointed by this Court to represent Petitioner Ronald See, e.g., Russell v. Lanier, 404 Fed. Appx. 288, 290 (10th Cir. 2010); U.S. v. Williams, 445 F.3d 724, 738 (4th Cir. 2006).
5. Opposing counsel informs me that, based upon my representation to him respecting the content of Exhibit D, he will not object to my request that this Exhibit be submitted for the Court's consideration under seal, albeit with a copy also provided to him. By so agreeing, opposing counsel does not concede that the information contained in Exhibit D is relevant to any of the issues presented in the pending Motion to Dismiss for Failure to Prosecute and Failure to Comply With the Court's Order.
Executed on the 10th of February, 2012, at Bolinas, Marin County, California. 5
/s/ Margaret Littlefield
Based on the stipulation of the parties and the Declaration of Counsel set 9 forth herein, and for good cause shown, the Court should order that Exhibit D to 10 the Declaration of Counsel in Support of Petitioner's Opposition to the Motion to Dismiss be filed and maintained under seal.
© 1992-2012 VersusLaw Inc.