United States District Court, W.D. Washington, Seattle
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,
SAFEGUARD PROPERTIES, LLC, a Delaware corporation, Defendant.
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.
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
STATEMENT OF FACTS
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).
will file the following as exhibits to the Supplemental
Declaration of Clay M. Gatens in Support of Plaintiffs'
Motion for Class Certification ("Supp. Gatens.
• Exhibit H, "scorecard" report to one of
• 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.
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
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.