Free Motion to Seal Document - District Court of Colorado - Colorado

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

Document 24

Filed 06/24/2005

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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 FILE UNDER SEAL DEFENDANTS' COMBINED RESPONSE TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS and DEFENDANTS' MOTION FOR PROTECTIVE ORDER AND REQUEST FOR SANCTIONS

Defendants, Joe Thomas and the City of Edgewater, by their counsel, Nathan, Bremer, Dumm & Myers, P.C., pursuant to D.C.Colo.LCivR 7.2, move to file under seal their Combined Response to Plaintiff's Motion to Compel Discovery and Request for Sanctions, and Defendants' Motion for Protective Order and Request for Sanctions: CERTIFICATION OF COMPLIANCE WITH D.C.Colo.LCivR 7.1 Undersigned counsel for Defendants conferred with counsel for the Plaintiff, and there is no objection to filing the Combined Response to Plaintiff's Motion to Compel Discovery and Request for Sanctions, and Defendants' Motion for Protective Order and Request for Sanctions.

H:\CASES\cirperry.jan\Pleadings\Motion to File Combined Response to Motion to Compel.doc

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

Document 24

Filed 06/24/2005

Page 2 of 4

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 information produced and disclosed as part of this litigation. Any information designated as confidential is protected from public disclosure. Pursuant to the protective order, if it is

necessary for the parties to file confidential information with the Court in any motion, the confidential information shall be filed under seal in accordance with D.C.Colo.LCivR 7.2. 2. The contemporaneously filed Combined Response to Plaintiff's Motion to Compel

Discovery and Requests for Sanctions, and Defendants' Motion for Protective Order and Requests for Sanctions includes materials subject to the protective order which are marked confidential. 3. The sealing of the combined response and motion is necessary to protect the

privacy and confidentiality of Defendant Thomas.

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

Document 24

Filed 06/24/2005

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REQUEST FOR RELIEF Defendants City of Edgewater and Thomas move for an Order sealing the Combined Response to Plaintiff's Motion to Compel Discovery and Requests for Sanctions, and Defendants' Motion for Protective Order and Requests for Sanctions. Respectfully submitted this 24th day of June, 2005.

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

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

Document 24

Filed 06/24/2005

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CERTIFICATE OF SERVICE I hereby certify that on this 24th day of June, 2005, I electronically filed the foregoing MOTION TO FILE UNDER SEAL DEFENDANT'S COMBINED RESPONSE TO PLAINTIFF'S MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS, AND DEFENDANTS' MOTION FOR PROTECTIVE ORDER AND REQUEST FOR SANCTIONS 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 Bernard Woessner J. Andrew Nathan NATHAN, BREMER, DUMM & MYERS, P.C. 3900 E. Mexico, Suite 1000 Denver, CO 80210 Telephone: (303) 691-3737 FAX: (303) 757-5106 Attorneys for Defendants

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