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

Case 1:03-cv-02485-MSK-PAC

Document 391

Filed 05/08/2006

Page 1 of 2

UNITED STATES DISTRICT COURT DISTRICT OF COLORADO CASE NO. 03-cv-02485 MSK-PAC CAMILLE MELONAKIS-KURZ, individually and on behalf of other similarly situated employees, and other individuals who have consented to join this action, Plaintiffs, v. HEARTLAND HOME FINANCE, INC., Defendant. UNOPPOSED JOINT MOTION TO FILE EXHIBIT UNDER SEAL ______________________________________________________________________________ The parties, by and through their attorneys, respectfully request that Exhibit A to their Stipulation of Settlement be filed under Seal. In support of this Unopposed Joint Motion, the parties state as follows: 1. 2. Concurrently herewith, the parties are filing their Stipulation of Settlement. Exhibit A to the Stipulation of Settlement contains information regarding

settlement terms that the parties have agreed shall remain confidential, but 3. As is stated in the Stipulation, the parties are jointly moving the Court for

approval of the settlement. Accordingly, in order to facilitate Court approval of the settlement, while at the same time maintaining the agreed upon confidentiality of the settlement terms, counsel for the parties have conferred and have agreed to file this joint motion respectfully requesting that Exhibit A be filed under seal. WHEREFORE, the parties, by counsel, jointly request that Exhibit A to their Stipulation of Settlement be filed under seal.

Case 1:03-cv-02485-MSK-PAC

Document 391

Filed 05/08/2006

Page 2 of 2

Dated: 05/08/2006 NICHOLS KASTER & ANDERSON, PLLP

Dated: 05/08/2006 ICE MILLER LLP

/s Michele R. Fisher Donald H. Nichols, MN #78918 Paul J. Lukas, MN #22084X Michele R. Fisher, MN #303069 Attorneys for Plaintiffs 4600 IDS Center Minneapolis, MN 55402 Telephone: (612) 338-1919 ATTORNEYS FOR PLAINTIFFS

/s David J. Carr David J. Carr, IN #4241-49 Steven F. Pockrass, IN #18836-49 One American Square Suite 3100 Indianapolis, IN 46282 Telephone: (317) 236-2100 Sean R. Gallagher HOGAN & HARTSON, LLP 1200 Seventeenth Street, Suite 150 Denver, CO 80202 Telephone: (303) 454-2415 ATTORNEYS FOR DEFENDANT

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