Court filing
Administrative Motion to File Under Seal PLAINTIFFS ADMINISTRATIVE… — Brooks v. Thomson Reuters Corporation (Dkt. 158)
Summary
In Document 158, filed 02/06/23 in Case No. 3:21-cv-01418-EMC-KAW before Hon. Edward M. Chen, Plaintiffs file an administrative motion to consider whether another party's materials should be sealed. They say Defendant designated as Confidential or Highly Confidential - Attorneys' Eyes Only an exhibit to Andre M. Mura's declaration supporting Plaintiffs' Omnibus Motion to Exclude Expert Opinions on Class Certification, the Kivetz Deposition, and list the provisionally sealed portions. They also list portions of their Motion to Exclude that quote from that exhibit or from expert reports submitted under seal by Defendant. For each item the table says Defendant is to provide evidence per the sealing rule.
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Cite this document
“Administrative Motion to File Under Seal PLAINTIFFS ADMINISTRATIVE… — Brooks v. Thomson Reuters Corporation (Dkt. 158).”
Original at ecf.cand.uscourts.gov, No. 3:21-cv-01418-EMC, Doc. 158. Archived at Pandemic Darlings, https://pandemicdarlings.com/court-filings/full-docket-brooks-thomsonreuters-cand-374304/2023-02-06-gov-uscourts-cand-374304-158-0-gov-uscourts-cand-374304-158-0/
, SHA-256 809cf9db7d28b67f0fe5090a11876adfcb7f42a8d33d3c813809055d40ec53ae.Full text
Case 3:21-cv-01418-EMC Document 158 Filed 02/06/23 Page 1 of 4
1 Eric H. Gibbs (SBN 178658) Geoffrey A. Graber (SBN 211547)
Andre M. Mura (SBN 298541) Karina G. Puttieva (SBN 317702)
2
Amy M. Zeman (SBN 273100) COHEN MILSTEIN SELLERS & TOLL
3 Mark H. Troutman (pro hac vice) PLLC
Ezekiel S. Wald (SBN 341490) 1100 New York Ave. NW, Fifth Floor
4 Washington, DC 20005
Hanne Jensen (SBN 336045)
5 GIBBS LAW GROUP LLP Telephone: (202) 408-4600
1111 Broadway, Suite 2100 Facsimile: (202) 408-4699
6 Oakland, CA 94607 ggraber@cohenmilstein.com
7 Telephone: (510) 350-9700 kputtieva@cohenmilstein.com
Facsimile: (510) 350-9701
8 ehg@classlawgroup.com
9 amm@classlawgroup.com
amz@classlawgroup.com
10 mht@classlawgroup.com
11 zsw@classlawgroup.com
hj@classlawgroup.com
12
13 Attorneys for Plaintiffs and the Proposed Class
14
15
UNITED STATES DISTRICT COURT FOR THE
16 NORTHERN DISTRICT OF CALIFORNIA
17 SAN FRANCISCO DIVISION
18 CAT BROOKS and RASHEED SHABAZZ, Case No. 3:21-cv-01418-EMC-KAW
individually and on behalf of all others
19
similarly situated, PLAINTIFFS’ ADMINISTRATIVE
20 MOTION TO CONSIDER WHETHER
Plaintiffs, ANOTHER PARTY’S MATERIALS
21
v. SHOULD BE SEALED
22
THOMSON REUTERS CORPORATION, Hon. Edward M. Chen
23
24 Defendant.
25
26
27
28
PLAINTIFFS’ ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER
PARTY’S MATERIALS SHOULD BE SEALED
Case No. 3:21-cv-01418-EMC-KAW
Case 3:21-cv-01418-EMC Document 158 Filed 02/06/23 Page 2 of 4
1 Pursuant to Civil Local Rule 79-5(f) and the Stipulated Protective Order entered by
2 the Court on December 17, 2021 (ECF No. 70), Plaintiffs request that the Court consider
3 whether material designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL –
4 ATTORNEYS’ EYES ONLY” should be filed under seal. Specifically, Defendant has
5 designated as “CONFIDENTIAL” or “HIGHLY CONFIDENTIAL – ATTORNEYS’ EYES
6 ONLY” the following exhibits to Andre M. Mura’s Declaration in Support of Plaintiffs’
7 Omnibus Motion to Exclude Expert Opinions on Class Certification:
8 Exhibit to Document Provisionally Evidence Offered in
Mura Sealed Support of Sealing
9
Declaration Portion(s)
10 Ex. 1 Kivetz Deposition 26:19-27:2; Def. to provide
27:16-28:5; evidence per Local Rule
11
40:5-40:23; 79-5(f)
12 41:18-41:20
13
The following portions of Plaintiffs’ Motion to Exclude quote from or otherwise refer
14
to the above exhibits and so may also be potentially considered confidential by Defendant:
15
Provisionally Sealed Portion of Motion Evidence Offered in Support of Sealing
16
Page 9, line 27 (between “generating” and Def. to provide evidence per L.R. 79-5(f)
17
“of”)
18
19 The following portions of Plaintiffs’ Motion to Exclude quote from or otherwise refer
20 to expert reports that were submitted under seal by Defendant and so may also be
21 potentially considered confidential by Defendant:
22 Provisionally Sealed Portion of Motion Evidence Offered in Support of Sealing
23 Page 3, lines 9-10 (between “here” and end Def. to provide evidence per L.R. 79-5(f)
of sentence)
24
Page 3, lines 11-12 (between “harms” and Def. to provide evidence per L.R. 79-5(f)
25 end of sentence)
26 Page 3, lines 12-14 (between “that” and end Def. to provide evidence per L.R. 79-5(f)
of sentence)
27 Page 3, lines 14-15 (between “fourth,” and Def. to provide evidence per L.R. 79-5(f)
end of sentence)
28
1
PLAINTIFFS’ ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER
PARTY’S MATERIALS SHOULD BE SEALED
Case No. 3:21-cv-01418-EMC-KAW
Case 3:21-cv-01418-EMC Document 158 Filed 02/06/23 Page 3 of 4
1 Page 4, lines 1-2 (between “that” and end Def. to provide evidence per L.R. 79-5(f)
of sentence)
2
Page 4, lines 4-5 (from start of line to end of Def. to provide evidence per L.R. 79-5(f)
3 sentence)
Page 4, line 5 (between “of” and “is”) Def. to provide evidence per L.R. 79-5(f)
4
Page 4, lines 21-22 (between “case” and end Def. to provide evidence per L.R. 79-5(f)
5 of sentence)
Page 5, line 8 (between “Kivetz’s” and end Def. to provide evidence per L.R. 79-5(f)
6
of line)
7 Page 6, line 13 (between “mischaracterizes Def. to provide evidence per L.R. 79-5(f)
as a” and “only”)
8
Page 6, line 13 (between “necessitates” and Def. to provide evidence per L.R. 79-5(f)
9 end of sentence)
Page 6, lines 14-16 (between “show that” to Def. to provide evidence per L.R. 79-5(f)
10
end of sentence)
11 Page 6, lines 18-20 (between “why” to “or Def. to provide evidence per L.R. 79-5(f)
know”)
12
Page 7, line 16 (between “consumers’” and Def. to provide evidence per L.R. 79-5(f)
13 “when Californians”)
Page 8, line 19 (from beginning of line to Def. to provide evidence per L.R. 79-5(f)
14
“with the implication”)
15 Page 8, lines 25-26 (between “marketplace,” Def. to provide evidence per L.R. 79-5(f)
to “ECF No. 151-14”)
16
Page 8, line 27 (from beginning of line to Def. to provide evidence per L.R. 79-5(f)
17 end of sentence)
Page 9, lines 4-6 (from “speculate that” to Def. to provide evidence per L.R. 79-5(f)
18
end of sentence)
19 Page 10, line 11 (between “survey by” and Def. to provide evidence per L.R. 79-5(f)
“—without”)
20
Page 10, lines 14-15 (between “questions Def. to provide evidence per L.R. 79-5(f)
21 such as” and “without offering”)
Page 10, lines 22.5-23.5 (from “arguing that Def. to provide evidence per L.R. 79-5(f)
22
because” to end of sentence)
23 Page 11, lines 12-13 (between “Turow” to Def. to provide evidence per L.R. 79-5(f)
“and that”)
24
Page 11, line 13 (between “position is” and Def. to provide evidence per L.R. 79-5(f)
25 “and”)
Page 11, line 13 (from “and” to end of Def. to provide evidence per L.R. 79-5(f)
26
sentence)
27 Page 14, lines 4-6 (quotation in Def. to provide evidence per L.R. 79-5(f)
parenthetical)
28
2
PLAINTIFFS’ ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER
PARTY’S MATERIALS SHOULD BE SEALED
Case No. 3:21-cv-01418-EMC-KAW
Case 3:21-cv-01418-EMC Document 158 Filed 02/06/23 Page 4 of 4
1 Pursuant to Local Rule 79-5(f)(3), Defendant, as the Designating Party, bears the
2 responsibility to establish that its designated materials are sealable. Plaintiffs provisionally
3 file these documents under seal to give Defendant an opportunity to specify any reasons
4 for keeping the documents under seal pursuant to Local Rule 79-5(c).
5
DATED: February 6, 2023 Respectfully submitted,
6
/s/ Andre M. Mura
7
Andre M. Mura
8
Eric H. Gibbs (SBN 178658)
9
Andre M. Mura (SBN 298541)
10 Amy M. Zeman (SBN 273100)
Mark H. Troutman (pro hac vice)
11 Ezekiel S. Wald (SBN 341490)
12 Hanne Jensen (SBN 336045)
GIBBS LAW GROUP LLP
13 1111 Broadway, Suite 2100
14 Oakland, California 94607
Telephone: (510) 350-9700
15 Facsimile: (510) 350-9701
16 ehg@classlawgroup.com
amm@classlawgroup.com
17 amz@classlawgroup.com
18 mht@classlawgroup.com
zsw@classlawgroup.com
19 hj@classlawgroup.com
20
Geoffrey A. Graber (SBN 211547)
21 Karina G. Puttieva (SBN 317702)
COHEN MILSTEIN SELLERS & TOLL
22
PLLC
23 1100 New York Ave. NW, Fifth Floor
Washington, DC 20005
24
Telephone: (202) 408-4600
25 Facsimile: (202) 408-4699
ggraber@cohenmilstein.com
26 vnugent@cohenmilstein.com
27 kputtieva@cohenmilstein.com
28 Attorneys for Plaintiffs and the Proposed Class
3
PLAINTIFFS’ ADMINISTRATIVE MOTION TO CONSIDER WHETHER ANOTHER
PARTY’S MATERIALS SHOULD BE SEALED
Case No. 3:21-cv-01418-EMC-KAW
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