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

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

Document 76

Filed 12/02/2005

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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 NOTICE OF PRODUCTION OF MEDICAL RECORDS UNDER SEAL _____________________________________________________________________________ Plaintiff, by and through his undersigned attorney, respectfully requests that this Court grant him leave to file the attached Notice of Filing of Medical Records, and the attached medical report, under seal, and, as grounds therefore states as follows: 1. 2. The Court held a hearing in this matter on November 22, 2005. At that hearing, the Court ordered that Plaintiff produce full medical by November

22, 2005. A Notice of Production of those records, along with the records, is attached. 3. Those records contain extremely confidential medical information about Plaintiff

that would be of no interest to any person except parties to this litigation. 4. At the hearing, the Court indicated that medical records could be filed with a

motion to seal. Counsel for Defendant did not object. WHEREFORE, the undersigned, on behalf of Plaintiff, respectfully requests that the Court grant Plaintiff leave to file the attached Notice of Production of Medical Records, and the attached medical records, under seal.

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

Document 76

Filed 12/02/2005

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DATED this 2nd day of December, 2005.

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 76

Filed 12/02/2005

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CERTIFICATE OF SERVICE I hereby certify that on December 2, 2005, 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]. In addition, the Notice of Production and the medical records attached thereto were separately e-mailed to: Colleen Meyers Rea, Esq., [email protected].

s/ Patricia S. Bangert _____________________________ Patricia S. Bangert

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