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

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li IACKSONWHITE
2] ATTORNEYS AT LAW
A Pr0)[ess1`0n¢z] Corporation
I
40 North Center Street, Suite 200 1
4 Mesa, Arizona 85201 A
(480) 464-1111
5 I/Xttorneys for Plaintiffs ¤
{By: Michael R. Pruitt, No. 011792 P
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IN THE UNITED STATES DISTRICT COURT ;
7
FOR THE DISTRICT OF ARIZONA
8
iiConnie Alms, a single woman, Case No. CIV 04-0332 PHX JW S
9
i Plaintiff, JOINT MOTION TO SEAL
10 PLAINTIFF’S CONTROVERTING
vs. AND SEPARATE STATEMENT OF
11 FACTS IN SUPPORT OF
AdvancePCS, a Delaware corporation, RESPONSE IN OPPOSITION TO
12 n/k/a CaremarkRx, Inc., a Delaware MOTION FOR SUMMARY
corporation, JUDGMENT ALONG WITH
13 DESIGNATED PLAINTIFF AND i
Defendant. DEFENDANT EXHIBITS
14 CONTAINING PRIVATE
INFORMATION AND FOR
15 SUBSTITUTION OF PLAINTIFF’S
AMENDED CONTROVERTING
16 AND SEPARATE STATEMENT OF `
it FACTS IN SUPPORT OF ,
17 RESPONSE IN OPPOSITION TO
MOTION FOR SUMMARY
18 JUDGMENT
19 &
20 Plaintiff, Connie Alms, and Defendant AdvancePCS, by and through their
21 undersigned counsel, in order to comply with the Court°s Order of June 23, 2006 regarding
V 22 the parties inclusion of private personal information in court filings available on the Internet,
Q 23 llrespectfully request the Court to enter an order sealing the following documents:
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5 24 M 1) Plaintiffs Controverting and Separate Statement of Facts in Support of Response i Q
O lg
QQ ig 25 1in Opposition to Motion for Summary Judgment (Docket # 57); _
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liaise 2:04-cv-00332-JWS Document 72 Filed 06/30/2006 Page 1 of 4 1
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1 2) Exhibit 1 attached to Plaintiffs Controverting and Separate Statement of Facts in
2 i§Support of Response in Opposition to Motion for Summary Judgment (Docket # 57,
3 iiAttachment # 1);
4J 3) Exhibit 2 attached to Plaintiffs Controverting and Separate Statement of Facts in
5 Support of Response in Opposition to Motion for Summary Judgment (Docket # 57,
6 Attachment # 2);
7 4) Exhibit 7 attached to Plaintiffs Controverting and Separate Statement of Facts in
8i$Support of Response in Opposition to Motion for Summary Judgment (Docket # 57,
9 {Attachment # 7);
10 5) Exhibit 10 attached to Plaintiffs Controverting and Separate Statement of Facts
11 lin Support of Response in Opposition to Motion for Summary Judgment (Docket # 57,
12 iAttachment # 10);
13 6) Exhibit 11 attached to Plaintiffs Controverting and Separate Statement of Facts
14win Support of Response in Opposition to Motion for Summary Judgment (Docket # 57 ,
15 Attachment # ll);
16 7) Exhibit 12 attached to Plaintiffs Controverting and Separate Statement of Facts
17 in Support of Response in Opposition to Motion for Summary Judgment (Docket # 57,
18 Attachment # 12);
19 i 8) Exhibit 1 attached to Defendant°s Statement of Facts in Support of its Motion for
20 i Summary Judgment (Docket # 52, Attachment it 2); p
21 i 9) Exhibit 2 attached to Defendanfs Statement of Facts in Support of its Motion for
3 22 Summary Judgment (Docket # 52, Attachment # 3);
{gi 23 10) Exhibit 5 attached to Defendanfs Statement of Facts in Support of its Motion for i
24% Summary Judgment (Docket # 52, Attachment # 6); ¥
g 25 1 1) Exhibit 6 attached to Defendant’s Statement of Facts in Support of its Motion for
fri; 26 Summary Judgment (Docket # 52, Attachment # 7);
ase 2:04-cv—00332-JWS Document 72 2 Filed 06/30/2006 Page 2 of 4 i

1 E 12) Exhibit 7 attached to Defendanfs Statement of Facts in Support of its Motion for
2 §Summary Judgment (Docket # 52, Attachment # 8); and
3 E? 13) Exhibit 8 attached to Defendant’s Statement of Facts in Support of its Motion for
4 llSummary Judgment (Docket # 52, Attachment # 9);
5 ll ln addition the parties also request the Court to allow Plaintiff to file Plaintiffs
6 lAmended Controverting and Separate Statement of Facts in Support of Response in
7 Opposition to Motion for Summary Judgment attached herein as Exhibit 1 solely for the
8 purpose of removing a single reference to Plaintiffs date of birth and replace it with
9 Plaintiff s year of birth and direct the Clerk ofthe Court to substitute the amended document
10 for the sealed Plaintiffs Controverting and Separate Statement of Facts in Support of
11 Response in Opposition to Motion for Summary Judgment.
12
13 _ RESPECTFULLY SUBMITTED this 30* day of June, 2006.
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15
16 ‘ JACKSON WHITE LITTLER ME DELSON M ,
,14,,,.) %€`A..»& w‘“"•’*;;;_,
17 By: s/Michael R. Pruitt, Esq. By: s/ Christie L. Kriegsfeld, Esg.
40 North Center Street, Suite 200 2425 East Camelback Road, Suite 900
18 Mesa, Arizona 85201 Phoenix, Arizona 85016
Attorneys for the Plaintiffs Attorneys for Defendants
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1 CERTIFICATE OF SERVICE i
2*} I hereby certify that on June 30, 2006, I electronically transmitted the attached ` A
i documents to the Clerk’s Office using the CM/ECF System for filing and transmitted a .
3 1ENotice of Electronic Filing to the following CM/ECP registrants: A
4 Steven Gregory Biddle A
5 Littler Mendelson PC I
2425 E Camelback Rd, Ste 900
6 {Phoenix, AZ 85016-2907
7 fsbiddle{culittler.com
I
gi s/ Michael R. Pruitt
Michael R. Pruitt
9
10 COPY of the foregoing mailed and e—mailed
§,this 30"‘ day of June, 2006, to:
ll it
llThe Honorable John W. Sedwick
12
Mllnited States District Court
13 -i222 W. 7"‘ Avenue # 4
Ma Anchorage, AK 99513
15 i By s/ Michael R. Pruitt
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