Unopposed Administrative Motion to File Under Seal — Kiara Moore — Mount Zion Baptist Church, No. 3:22-cv-00965

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An unopposed administrative motion to file under seal, filed November 17, 2023 as Document 68 in Kiara Moore v. Mount Zion Baptist Church, Joseph W. Walker, III, and Stephaine Walker, Case No. 3:22-cv-00965, in the U.S. District Court for the Middle District of Tennessee, Nashville Division (Judge Trauger). It recounts that the parties notified the court on October 20, 2023 that they had executed a term sheet resolving the plaintiff's claims against all defendants, that the court ordered a stipulation of dismissal or settlement document within thirty days on October 23, 2023, and that the parties executed a formal settlement agreement on October 24, 2023. Relying on the local rules and the stipulated protective order (Docket No. 21), the plaintiff conditionally lodges under seal documents containing confidential or privileged information.

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UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF TENNESSEE
NASHVILLE DIVISION

KIARA MOORE, Case No. 3:22-cv-00965
Plaintiff,

Judge Trauger

Vv.

MOUNT ZION BAPTIST CHURCH,
JOSEPH W. WALKER, III, and
STEPHAINE WALKER,

)
)
)
)
)
) UNOPPOSED ADMINISTRATIVE MOTION
) TO FILE UNDER SEAL

)

)

)

)

Defendant.

Plaintiff Kiara Moore (“Plaintiff”) submits this Unopposed Administrative Motion to File
Under Seal pursuant to Local Rules 5.03 and 7.01, Section 5.07 of Administrative Order No.
167-1, and the Stipulated Confidentiality Agreement And Order (‘Protective Order”) (Docket
No. 21).

I. Plaintiff Conditionally Lodges Under Seal Documents Which Contain Confidential
Or Privileged Information

On October 20, 2023, the Parties notified this Court that they “executed a Term Sheet
that resolves Plaintiffs claims against all named Defendants,” and that “the Parties have and
continue to work expeditiously to prepare and execute a formal settlement agreement.” (Docket
No. 59.) On October 23, 2023, this Court issued an Order requiring “that a stipulation of
dismissal or other settlement document shall be filed within thirty (30) days.” (Docket No. 60.)
On October 24, 2023, the Parties executed a formal settlement agreement (the “Settlement

Agreement’). The terms of the Settlement Agreement are confidential.

UNOPPOSED ADMINISTRATIVE MOTION TO FILE UNDER SEAL Page 1
Case 3:22-cv-00965 Document68 _ Filed 11/17/23. Page 1 of 4 PagelD #: 1246
Plaintiff hereby notifies the Court that she has conditionally filed six (6) documents under
seal in connection with Plaintiff's Motion for Attorneys’ Fees and Reimbursement of Expenses
(“Fee Petition”):

1. Plaintiff's Memorandum in Support of Motion for Attorneys’ Fees and
Reimbursement of Expenses (the “Memorandum’’);

2. Declaration of Kiara Moore in Support of Plaintiff's Motion for Attorneys’ Fees
and Reimbursement of Expenses (“Plaintiff Decl.”);

3. Declaration of William D. Harris II in Support of Plaintiff's Motion for
Attorneys’ Fees and Reimbursement of Expenses (“Harris Decl.”’);

4. The Settlement Agreement, which is attached as Exhibit A to the Harris Decl.;

5. The billing records and expenses for Harris Legal Advisors LLC (“HLA Billing
Records”), which are attached as Exhibit H to the Harris Decl.; and

6. The billing records and expenses for Sherrard Roe Voigt & Harbison, PLC,
(“SRVH Billing Records”) which are attached as Exhibit I to the Sabis Decl.

II. The Terms of the Settlement Agreement Are Confidential

The Parties have agreed to keep the terms of the Settlement Agreement confidential.
Pursuant to the Court’s October 23, 2023 Order (Docket No. 60), the Settlement Agreement is
attached as Exhibit A to the Declaration of William D. Harris II In Support of this Unopposed
Administrative Motion to Seal (“Harris Seal Decl.’’) so that it may be reviewed in camera by the
Court. However, because the terms are confidential, the Settlement Agreement was not filed
publicly with the Fee Petition. Rather, a slip sheet stating that Exhibit A to the Harris Decl. was

“Filed Under Seal.”

UNOPPOSED ADMINISTRATIVE MOTION TO FILE UNDER SEAL Page 2
Case 3:22-cv-00965 Document68 - Filed 11/17/23. Page 2 of 4 PagelD #: 1247
The Memorandum, Plaintiff Decl., and Harris Decl., were redacted to the extent they
would otherwise disclose one or more terms of the Settlement Agreement, or otherwise contain
information that could be used to ascertain one or more terms of the Settlement Agreement.

Il. The HLA Billing Records and SRVH Billing Records Contain Information
Protected from Disclosure by the Attorney-Client Privilege

“{I|nformation covered by a recognized privilege (such as the attorney-client privilege)
... 1S typically enough to overcome the presumption of public access.” Local Rule 5.03(a).
Plaintiff's Counsel submitted their detailed billing records in support of the Fee Petition. The
HLA Billing Records and SRVH Billing Records contain detailed time records which describe
communications between Plaintiff and her Counsel. This information is protected from
disclosure by the attorney-client privilege. The HLA Billing Records and SRVH Billing Records
submitted with the Fee Petition have been redacted to preserve the attorney-client privilege.

IV. The Memo and Plaintiff Decl. Contain Confidential Information about Plaintiff's
Income

Plaintiff Decl. and the Memorandum identify the amount of Plaintiff's annual income
prior to the Adverse Employment Action giving rise to this litigation. See First Amended
Complaint, Docket No. 28, at § 42. This information has been redacted from Plaintiff Decl. and
the Memorandum to protect Plaintiffs confidential information.

This Motion is also based on the information set forth in the Harris Seal Decl., filed

concurrently herewith.

Dated: November 17, 2023 Respectfully Submitted,
/s/ Christopher C. Sabis
Christopher C. Sabis (Bar No. 030032) William D. Harris II, Pro Hac Vice
SHERRARD ROE VOIGT & HARBISON, PLC Ryan P. Wagenleitner, Pro Hac Vice
150 3rd Avenue South, Suite 1100 HARRIS LEGAL ADVISORS LLC
Nashville, Tennessee 37201 605 N. High Street, Suite 146
UNOPPOSED ADMINISTRATIVE MOTION TO FILE UNDER SEAL Page 3

Case 3:22-cv-00965 Document68 _ Filed 11/17/23. Page 3 of 4 PagelD #: 1248
Phone: (615) 742-4200 Columbus, Ohio 43215

Facsimile: (615) 742-4539 Phone: (614) 504-3350
Email: csabis@srvhlaw.com Facsimile: (614) 340-1940
Email: will@harrislegaladvisors.com
Attorneys for Plaintiff Email: ryan@harrislegaladvisors.com
UNOPPOSED ADMINISTRATIVE MOTION TO FILE UNDER SEAL Page 4

Case 3:22-cv-00965 Document68 _ Filed 11/17/23. Page 4 of 4 PagelD #: 1249


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