Kirkpatrick v. Alderwoods Group, Inc. et al

Western District of Texas, txwd-6:2011-cv-00238

SEALING ORDER [Transferred from California Northern on 9/7/2011.]

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IC&sess:08+&+60-0104BSIWSISodoremne68163Fifele 059561900049 Pagege of 3 STEVEN H. GURNEE, ESQ. SB# 66056 JOHN A. MASON, ESQ. GURNEE & DANIELS LLP 2240 Douglas Boulevard, Suite 150 Roseville, CA 95661-3805 Telephone (916) 797-3100 Facsimile (916) 797-3131 | Attorneys for Defendants SERVICE CORPORATION INTERNATIONAL, SCI FUNERAL AND CEMETERY PURCHASING COOPERATIVE, INC., SCI EASTERN MARKET SUPPORT CENTER, L.P. SCI WESTERN MARKET SUPPORT CENTER, L.P., SCI HOUSTON MARKET SUPPORT CENTER, L.P. JANE D. JONES, GWEN PETTEWAY, THOMAS RYAN, CURTIS BRIGGS, ALDERWOODS GROUP, INC., and PAUL HOUSTON UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CLAUDE BRYANT, et al., on behalf of CASE NO. 3:08-CV-01190 SI themselves and all other employees and former) CASE NO. 3:08-CV-01184 SI employees similarly situated, STIPULATION TO FILE DOCUMENT) UNDER SEAL; [PROPOSED] ORDER Plaintiffs, vs. SERVICE CORPORATION INTERNATIONAL et al. Defendants. WILLIAM HELM, DEBORAH PRISE, HEATHER P. RADY, et al., on behalf of) themselves and all other employees and former) employees similarly situated, Plaintiffs, VS. STIPULATION TO FILE DOCUMENT UNDER SEAL; [PROPOSED) ORDER Case No.: 3:08-CV-01190 SI; Case No.: 3:08-CV-01184 SI Casas8:0816x604004BSIWSBocoreme68163Fifeiled5956/2019 Paynge ef3 ALDERWOODS GROUP, INC., PAUL A.) HOUSTON, SERVICE CORPORATION INTERNATIONAL, SCI FUNERAL AND CEMETERY PURCHASING COOPERATIVE, INC., SCI EASTERN MARKET SUPPORT CENTER, L.P., SCI) WESTERN MARKET SUPPORT CENTER,) L.P., a/k/a SCI WESTERN MARKET SUPPORT CENTER, INC., and SCI HOUSTON MARKET SUPPORT CENTER,) L.P. Defendants. STIPULATION Previously, Plaintiffs and Defendants agreed to, and the Court entered, a Stipulated Protective Order Pursuant to Fed. R. Civ. P. 26(C). (Bryant Docket No. 112; Helm Docket No. 124). That Protective Order, inter alia, set out a procedure permitting parties to designate certain discovery materials "CONFIDENTIAL." In response to discovery demands in this case, Defendants have designated certain documents "CONFIDENTIAL" || pursuant to the Protective Order, and Plaintiffs have not currently challenged some of those designations. Pursuant to Civil Local Rules 79-5 and 7-12, Plaintiffs and Defendants in these matters, through their undersigned counsel, hereby stipulate that in submitting Defendants' Reply in support of their pending motions to dismiss, Defendants may file under seal pursuant to the Protective Order the following documents, each of which has been designated "CONFIDENTIAL": 1. Defendants Service Corporation International, SCI Eastern Market Support Center, L.P., SCI Houston Market Support Center, L.P., Jane D. Jones, Gwen Petteway, Thomas Ryan and Curtis Briggs Reply in Support of Their Motion to Dismiss Complaint Pursuant to FRCP 12(B)(2) and FRCP 12(B)(6), which describes and quotes from materials Defendants have designated as "CONFIDENTIAL" 2. Defendants' Evidentiary Objections and Motion to Strike Portions of Plaintiffs' Consolidated Declaration of Sarah Cressman in Opposition to Defendants' Motions to Dismiss, for Partial Judgment on the Pleadings, and to Strike and Require a More Definite Statement and Motions for STIPULATION TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER Case No.: 3:08-CV-01190 SI; Case No.: 3:08-CV-01184 SI kasase:68267604010LBSIWSSodDoreme88163Fifeiled57501900190 Page @f@ 3 Stay and Award of Attorney Fees and Costs Pursuant to FRCP 41(d), which describes and quotes from materials Defendants have designated as "CONFIDENTIAL" AGREED TO: /s/Annette Gifford Annette Gifford Thomas & Solomon LLP 693 East Avenue Rochester, New York 14607 Telephone: (585) 272-0540 /s/Nicholas P. Forestiere Nicholas P. Forestiere Gurnee & Daniels LLP 2240 Douglas Blvd., Suite 150 Roseville, CA 95661 Telephone: (916) 797-3100 Attorneys for Plaintiffs Attorneys for Defendants ORDER Pursuant to the Stipulation of counsel and good cause appearing, the Court hereby orders that, in submitting Defendants' Reply in support of their pending motions to dismiss, Defendants may file under seal pursuant to the Protective Order the following documents, each of which has been designated "CONFIDENTIAL" by Defendants: 1. Defendants Service Corporation International, SCI Eastern Market Support Center, L.P., SCI Houston Market Support Center, L.P., Jane D. Jones, Gwen Petteway, Thomas Ryan and Curtis Briggs Reply in Support of Their Motion to Dismiss Complaint Pursuant to FRCP 12(B)(2) and FRCP 12(B)(6), which describes and quotes from materials Defendants have designated as "CONFIDENTIAL" 2. Defendants' Evidentiary Objections and Motion to Strike Portions of Plaintiffs' Consolidated Declaration of Sarah Cressman in Opposition to Defendants' Motions to Dismiss, for Partial Judgment on the Pleadings, and to Strike and Require a More Definite Statement and Motions for Stay and Award of Attorney Fees and Costs Pursuant to FRCP 41(d), which describes and quotes from materials Defendants have designated as "CONFIDENTIAL" IT IS SO ORDERED: Jusan A ston Honorable Susan Illston United States District Court STIPULATION TO FILE DOCUMENT UNDER SEAL; [PROPOSED] ORDER Case No.: 3:08-CV-01190 SI; Case No.: 3:08-CV-01184 SI