Free Motion for Order - District Court of Colorado - Colorado

Case 1:04-cv-01255-RPM-CBS

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No.: 04-CV-1255-RPM-CBS VERNA SUE PERRY, Plaintiff, v. OFFICER SHAWN OLIVETT, #0201, in her individual and official capacity, OFFICER JOE THOMAS, #0203, in his individual and official capacity, OFFICER STEVE VAN DE WEERT, #0202, in his individual and official capacity, THE CITY OF EDGEWATER, Colorado Defendants.

MOTION TO CLOSE COURT PROCEEDINGS TO THE PUBLIC

Defendants, City of Edgewater, Joe Thomas, and Steve Van de Weert, by their counsel, Nathan, Bremer, Dumm & Myers, P.C., pursuant to D.C. COLO. LCivR 7.2 move to close the hearing scheduled on July 15, 2005, at 11:00 a.m.: CERTIFICATION PURSUANT TO D.C. COLO. LCivR 7.1 Counsel for the Plaintiff objects to this motion. Counsel for Defendant Olivett does not object to this motion. MOTION 1. A Stipulation and Protective Order was entered in this case on September 24,

2004. The Stipulation and Protective Order allows parties to designate as confidential certain

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information produced and disclosed as part of this litigation.

Any information designated

confidential is protected from public disclosure. Pursuant to this Protective Order, a hearing addressing confidential information may be closed to the public pursuant to D.C. COLO. LCivR. 7.2. 2. The Court has scheduled a hearing regarding motions addressing the discovery

and production of confidential material on July 15, 2005. These motions, and necessarily the hearing, will address materials that are subject to the Protective Order and that are marked confidential. 3. Closing the hearing to the public is necessary to protect the privacy and

confidentiality of the Defendants. REQUEST FOR RELIEF Defendants, the City of Edgewater and Thomas, and Van de Weert move for an Order closing the hearing scheduled for July 15, 2005 to the public. Respectfully submitted,

/s/ Bernard Woessner J. Andrew Nathan Bernard Woessner NATHAN, BREMER, DUMM & MYERS, P.C. 3900 East Mexico Avenue, Suite 1000 Denver, CO 80210 Telephone: (303) 691-3737 Fax: (303) 757-5106 [email protected] Attorneys for Defendants 2

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CERTIFICATE OF SERVICE (CM/ECF) I hereby certify that on this 1st day of July , 2005, I electronically filed the foregoing Motion to Close Court Proceedings to the Public with the Clerk of Court using the CM/ECF system which will send notification of such filing to the following e-mail addresses: David Lane, Esq., [email protected] Cynthia Sheehan, Esq., [email protected] Thomas S. Rice, Esq., [email protected]

/s/ Bernard Woessner J. Andrew Nathan Bernard Woessner Attorneys for Defendants Nathan, Bremer, Dumm & Myers, p.c. 3900 East Mexico Avenue, Suite 1000 Denver, CO 80210 Telephone: (303) 691-3737 Fax: (303) 757-5106 [email protected]

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