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Bund v. Safeguard Properties, LLC

United States District Court, W.D. Washington, Seattle

August 14, 2017

JOHN R. BUND II, personally, as Executor of the Estate of Richard C. Bund, deceased; MANDY HANOUSEK and GARETT HANOUSEK, a married couple, and on behalf of others similarly situated, Plaintiff,
v.
SAFEGUARD PROPERTIES, LLC, a Delaware corporation, Defendant.

          LEE SMART, P.S., INC. Marc Rosenberg, WSBA No. 31034 Pamela J. DeVet, WSBA No. 32882 Of Attorneys for Defendant Safeguard Properties Management, LLC Lee Smart, P.S., Inc.

          JEFFERS, DANIELSON, SONN & AYLWARD, P.S. Clay M. Gatens, WSBA No. 34102 Sally F. White, WSBA No. 49457 Devon A. Gray, WSBA No. 51485 Jeffers, Danielson, Sonn & Aylward, P.S. Attorneys for Plaintiffs

          THIRD STIPULATED MOTION TO SEAL AND ORDER

          HONORABLE JAMES L. ROBART, UNITED STATES DISTRICT JUDGE.

         I. INTRODUCTION

         The Court previously granted the parties' stipulated motions to seal certain documents Plaintiffs filed in support of their motion for class certification, Dkt. # 89, 92. On August 4, 2017, Plaintiffs will file confidential documents with their reply brief. The parties ask that the Court seal them for the reasons in the two referenced Orders and as set forth below.

         II. STATEMENT OF FACTS

         On Thursday, August 4, 2017, Plaintiffs' counsel alerted Defendant's counsel that Plaintiffs' intend to file documents designated confidential pursuant to the protective order's enumerated category of defendant's policies and procedures. See Dkt. No. 68, p. 2:3-8 (¶ 2), p. 6:8-13 (¶ 5.3).

         Plaintiffs will file the following as exhibits to the Supplemental Declaration of Clay M. Gatens in Support of Plaintiffs' Motion for Class Certification ("Supp. Gatens. Decl."):

• Exhibit H, "scorecard" report to one of Defendant's clients;
• Exhibit I, vendor scorecard policy; and
• Exhibit J, "heat maps, " described as a geospatial representation of deficiencies in performance relative to work performed, normalized for volume.

         The parties conferred pursuant to LCR 5(g)(1)(A) on Thursday, August 4, 2017, to discuss and to explore alternatives to filing documents under seal. Attorneys Devon Gray (for Plaintiffs) and Pamela DeVet (for Defendant) conferred via telephone. The parties certify the foregoing pursuant to LCR 5(g)(3)(A).

         Plaintiffs do not challenge Defendant's confidentiality designations in connection with the documents they will file with the reply in support of their motion for class certification.

         III. ...


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