Free Motion to Seal - District Court of Connecticut - Connecticut

Case 3:03-cv—00986-JCH Document 143 Filed 08/24/2005 Page 1 of 3
UNITED STATES DISTRICT COURT
DISTRICT OF CONNECTICUT
SUSAN E. WOOD, CIVIL ACTION NO.
3:03-CV-986 (JCH)
Plaintiff,
- against -
SEMPRA ENERGY TRADING CORP.,
Defendant.
DEFENDANT’S MOTION TO FILE DOCUMENTS UNDER SEAL
Pursuant to L. Civ. R. 5(d) Defendant, Sempra Energy Trading Corp.
("Defendant"), hereby tiles this motion seeking this Court’s pennission to tile documents under
seal in the above—captioned matter. As stated in greater detail in the accompanying
Memorandum of Law, the documents at issue are 35 exhibits (10 affidavits and 25 client
documents) to be attached to Defendant’s Memorandum in Opposition to Plaintiff s Motion in
Limine (#96) (the "Sealed Exhibits").
Defendant hereby requests this Court consent to conduct an ex parte, in camera
review of the Sealed Exhibits as they are directly relevant to Defendant’s Opposition to
Plaintiff s Motion in Limine. As this Court directed the undersigned counsel to provide
information regarding the collection and preservation of documents related to this litigation, it is
imperative that this Court review the Sealed Exhibits. These documents, however, contain
Defendant”s counsel’s privileged work—product and attomey-client privileged communications.
This Court’s ex parte, in camera inspection ofthe Sealed Exhibits is necessary to maintain the
privilege status of these records.

Case 3:03-cv—00986-JCH Document 143 Filed 08/24/2005 Page 2 of 3
Therefore, for the reasons stated above, as well as those described in the
accompanying Memorandum of Law, Defendant respectfully requests this Court consent to
conduct an ex parte, in camera review ofthe Sealed Exhibits.
DATED: August 24, 2005 Respectfully submitted,
DEFENDANT SEMPRA ENERGY TRADING
CORP.
By: &J·
Mar§C. Dollarhide (ct1225l)
Raymond W. Bertrand (ct22968)
Paul, Hastings, Janofsky & Walker, LLP
1055 Washington Boulevard
Stamford, CT 06901-2217
Telephone: (203) 961-7400
Facsimile: (203) 359-3031
marydollarhidegaipaulhastingscom
rayinondbertrandgajipaulhasting s.conr
-2-

Case 3:03-cv—00986-JCH Document 143 Filed 08/24/2005 Page 3 of 3
CERTIFICATE OF SERVICE
This is to certify that on this 24th day of August 2005, a copy of the foregoing was
forwarded via hand deliver to counsel for the Plaintiff at the following address:
Brendan J. O’Rourke, Esq.
O’ROURKE & ASSOCIATES, LLC
27 Pine Street
New Canaan, CT 06840
c-
Ra ond W. Bertrand
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