Opinion
Case No. C-08-00177-SI
10-27-2011
JAMES BRADY, SARAH CAVANAGH, and IVA CHIU, individually and on behalf of all others similarly situated, Plaintiffs, v. DELOITTE & TOUCHE LLP, a limited liability partnership; and DOES 1-10, inclusive, Defendants
COUNSEL FOR DEFENDANT DELOITTE & TOUCHE LLP Linda E. Shostak James E. Boddy, Jr. MORRISON & FOERSTER LLP COUNSEL FOR PLAINTIFFS William A. Baird Daria Dub Carlson Jeffrey K. Compton MARKUN ZUSMAN & COMPTON, LLP Steven Elster LAW OFFICE OF STEVEN ELSTER
LINDA E. SHOSTAK (CA SBN 64599)
JAMES E. BODDY, JR. (CA SBN 65244)
MORRISON & FOERSTER LLP
Attorneys for Defendant
DELOITTE & TOUCHE LLP
MARKUN ZUSMAN & COMPTON LLP
Jeffrey K. Compton (SBN 142969)
Daria Dub Carlson (SBN 150628)
William A. Baird (SBN 192675)
LAW OFFICE OF STEVEN ELSTER
Steven Elster (SBN 227545)
Attorneys for Plaintiffs and the Certified Class
STIPULATION AND [PROPOSED]
ORDER TO UNSEAL SOLIS BRIEFS
Pursuant to Local Rule 7-12, Plaintiffs and Defendant Deloitte & Touche LLP ("Defendant"), through their respective counsel, submit the following stipulation and [proposed] order that certain pleadings, as described below, conditionally filed with the Court under seal be unsealed.
WHEREAS, in the course of the discovery Defendant has produced and disclosed confidential, proprietary, and other private information related to the parties, as well as Defendant's clients, designated "Confidential" or "Highly Confidential - Attorneys' Eyes Only" pursuant to the parties' Stipulated Protective Order signed by the Court on March 10, 2009, and filed in the above captioned action on March 11, 2009 ("Designated Produced Materials"), for which Defendant believes special protection from public disclosure and from use for any purpose other than prosecuting this litigation would be warranted;
WHEREAS, the parties have agreed that material designated as confidential, proprietary, and other private information related to the parties, as well as Defendant's clients, may be included in or discussed in the parties' filings with respect to Defendant's Motion for Class Decertification ("Designated Motion Materials");
WHEREAS, the parties agreed and the Court ordered pursuant to the parties' stipulations and proposed orders that Plaintiffs' Briefing re Solis v. Washington and Plaintiffs' Reply to Deloitte's Briefing re Solis v. Washington (collectively, "Solis Briefs") be conditionally filed under seal;
WHEREAS, the parties agreed that they would meet and confer regarding whether the documents filed under seal pursuant to said stipulations and orders should remain under seal; and
WHEREAS, the parties, having met and conferred, have agreed that the Court may order the Solis Briefs filed under seal to be unsealed, without prejudice to either parties' rights to maintain or not maintain under seal any other briefs or documents filed with the Court under seal and that said order shall not affect the under-seal status of any other briefs or documents filed with the Court under seal, including without limitation any exhibits referred to in the Solis Briefs.
NOW THEREFORE, the parties hereby stipulate, subject to Court approval, that the following briefs conditionally filed under seal herein be unsealed:
1. Plaintiffs' Briefing re Solis v. Washington; and
2. Plaintiffs' Reply to Deloitte's Briefing re Solis v. Washington.
IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.
COUNSEL FOR DEFENDANT
DELOITTE & TOUCHE LLP
Linda E. Shostak
James E. Boddy, Jr.
MORRISON & FOERSTER LLP
COUNSEL FOR PLAINTIFFS
William A. Baird
Daria Dub Carlson
Jeffrey K. Compton
MARKUN ZUSMAN & COMPTON, LLP
Steven Elster
LAW OFFICE OF STEVEN ELSTER
ECF CERTIFICATION
I hereby attest that I have obtained concurrence regarding the filing of this document from each of the signatories within the e-filed document.
James E. Boddy
PURSUANT TO STIPULATION, IT IS SO ORDERED.
Honorable Susan Illston
United States District Court Judge