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

Case 1:04-cv-00684-EWN-MEH

Document 86

Filed 01/26/2006

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO Civil Action No. 04-cv-00684-EWN-OES JOSEPH STEINBACH, JR. Plaintiff, v. OMNI PROPERTIES, INC., Defendant. _____________________________________________________________________________ UNOPPOSED MOTION TO FILE EXHIBIT UNDER SEAL _____________________________________________________________________________ Plaintiff, by and through his undersigned attorney, respectfully requests that this Court grant him leave to file the attached exhibit to Plaintiff's response to Defendant's motion for summary judgment under seal, and, as grounds therefore states as follows: 1. The Plaintiff filed a response to defendant's motion for summary judgment on

January 23, 2006. One of the attachments to that motion (Attachment 10) was deposition testimony by an employee of Defendant. Pursuant to a protective order issued by the Court in this matter, Defendant had designated the portion of the testimony included in the attachment as confidential, and asked that it be treated as such for all purposes. 2. For that reason, the Plaintiff desires to file the attachment to the summary

judgment motion under seal. 3. The Defendant does not object to this motion. It is Defendant's desire to have the

attachment held as confidential. WHEREFORE, the undersigned, on behalf of Plaintiff, respectfully requests that the

Case 1:04-cv-00684-EWN-MEH

Document 86

Filed 01/26/2006

Page 2 of 3

Court grant Plaintiff leave to file the attached exhibit to Plaintiff's response to Defendant's motion for summary judgment under seal. DATED this 26th day of January, 2006.

Respectfully submitted, s/ Patricia S. Bangert _______________________ Patricia S. Bangert, Esq. Special Counsel to Lohf, Shaiman, Jacobs, Hyman & Feiger, P.C. 950 S. Cherry Creek Street Suite 900 Denver, CO 80246 Phone: (303) 753-9000 Fax: (303) 753-9997 E-mail: [email protected] Attorney for Plaintiff

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Case 1:04-cv-00684-EWN-MEH

Document 86

Filed 01/26/2006

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on January 26, 2006, I electronically filed the foregoing to the Clerk using the CM/ECF system, which will send notification of such filing to the following: Colleen Meyers Rea, Esq., [email protected].

s/ Patricia S. Bangert _____________________________ Patricia S. Bangert

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