Proposed Order — Brooks v. Thomson Reuters Corporation (Dkt. 167.1)

Summary

Document 167-1, filed 03/06/23 in Case No. 3:21-cv-01418-EMC-KAW, is a proposed order on Plaintiffs' Administrative Motion to Consider Whether Another Party's Materials Should Be Sealed, relating to Plaintiffs' Opposition to Defendant's Motion to Exclude Expert Testimony of Finance Scholars Group, Inc. (Terry Lloyd). The proposed order would permit listed portions of the Lloyd Opposition and supporting documents to be filed under seal, with Defendant as the designating party for each. The list includes a Kidder deposition passage and a supplemental interrogatory response attached to the Mura declaration, and specific page and line portions of the opposition. The date line and the signature line for Edward M. Chen are blank.

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          Case 3:21-cv-01418-EMC              Document 167-1    Filed 03/06/23   Page 1 of 3



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                              UNITED STATES DISTRICT COURT FOR THE
10                              NORTHERN DISTRICT OF CALIFORNIA
                                     SAN FRANCISCO DIVISION
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12   CAT BROOKS and RASHEED SHABAZZ,                      Case No. 3:21-cv-01418-EMC-KAW
     individually and on behalf of all others similarly
13   situated,                                            [PROPOSED] ORDER RE: PLAINTIFFS’
                                                          ADMINISTRATIVE MOTION TO
14                                     Plaintiffs,        CONSIDER WHETHER ANOTHER
15          v.                                            PARTY’S MATERIALS SHOULD BE
                                                          SEALED
16   THOMSON REUTERS CORPORATION,
                                                          Hon. Edward M. Chen
17                                    Defendant.
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         [PROPOSED] ORDER RE: 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 167-1         Filed 03/06/23     Page 2 of 3



 1          Having considered Plaintiffs’ Administrative Motion to Consider Whether Another Party’s
 2   Materials Should Be Sealed, relating to Plaintiffs’ Opposition to Defendant’s Motion to Exclude Expert
 3   Testimony of Finance Scholars Group, Inc. (Terry Lloyd) (“Lloyd Opposition”), materials in support of
 4   that Motion, and any responses from the designating party, pursuant to Local Rule 79-5;
 5          IT IS HEREBY ORDERED:
 6          The following portions of Plaintiffs’ Lloyd Opposition and supporting documents may be filed
 7   under seal:
 8     Exhibit to Andre M. Mura Declaration in Support             Designating                 Ruling
          of Lloyd Opposition or Portion of Opposition                Party
 9    Ex. 1 to Mura Decl. (Kidder Depo.) 43:13-43:23             Defendant
10    Ex. 2 to Mura Decl. (Def.’s Fourth Supplemental            Defendant
      Answers and Objections to Plaintiffs’ Fist Set of
11    Interrogatories to Defendant)
      Lloyd Opposition, Page 2, line 14 (between “there was      Defendant
12    a” and “between”)
13    Lloyd Opposition, Page 2, line 17 (between “that if” and   Defendant
      “of CLEAR’s”
14    Lloyd Opposition, Page 2, line 18 (between “and” and       Defendant
      “were”)
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      Lloyd Opposition, Page 2, line 22 (between “were” and      Defendant
16    “then”)
      Lloyd Opposition, Page 6, lines 16-17 (entire              Defendant
17    parenthetical following “¶¶ 113-14”)
      Lloyd Opposition, Page 6, line 22 (between “To be” and     Defendant
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      “Kidder”)
19    Lloyd Opposition, Page 6, line 23 (between “allocated”     Defendant
      and end of sentence)
20    Lloyd Opposition, Page 8, line 10 (between “about” and     Defendant
      “of CLEAR’s”)
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      Lloyd Opposition, Page 8, line 11 (between “and” and       Defendant
22    “are”)
      Lloyd Opposition, Page 8, line 13 (between “them” and      Defendant
23    “to account”)
      Lloyd Opposition, Page 8, line 22 (between “to be” and     Defendant
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      “TR”)
25    Lloyd Opposition, Page 8, line 22.5 (between “with a”      Defendant
      and “search”)
26    Lloyd Opposition, Page 8, line 22.5 (between “field” and   Defendant
27    “percent”)
      Lloyd Opposition, Page 8, line 23.5 (between               Defendant
28    “summing” and “column”)
                                               1
         [PROPOSED] ORDER RE: 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 167-1       Filed 03/06/23   Page 3 of 3



 1   Lloyd Opposition, Page 8, lines 23.5-24 (between “sum   Defendant
     of” and “column”)
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 3   IT IS SO ORDERED.

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     DATED: ______________________                    ___________________________
 5                                                    EDWARD M. CHEN
 6                                                    United States District Judge

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                                              2
        [PROPOSED] ORDER RE: 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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