Free Motion to Seal - District Court of Colorado - Colorado

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

Document 65

Filed 11/11/2005

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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 MEDICAL REPORT 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 Report, and the attached medical report, under seal, and, as grounds therefore states as follows: 1. 2. The Court held a status conference on this matter on November 3, 2005. At that status conference, the undersigned discussed some health issues suffered

by the Plaintiff that will substantially impact his ability to assist in the preparation of his case for trial, and, may substantially impact or preclude his ability to participate in the trial. 3. The Court ordered that Plaintiff file a medical report on his condition by

November 11, 2005. 4. At the status conference, the Court granted Plaintiff permission to file a motion

requesting that the medical report be filed under seal, the Court not indicating how it would rule on such a motion. Counsel for Defendant indicated that she did not object to that motion at the conference.

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

Document 65

Filed 11/11/2005

Page 2 of 3

WHEREFORE, the undersigned, on behalf of Plaintiff, respectfully requests that the Court grant Plaintiff leave to file the attached Notice of Filing of Medical Report, and the attached medical report, under seal. DATED this 11th day of November, 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 65

Filed 11/11/2005

Page 3 of 3

CERTIFICATE OF SERVICE I hereby certify that on November 11, 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]

s/ Patricia S. Bangert _____________________________ Patricia S. Bangert

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