Rupa Marya v. Warner Chappell Music Inc

Filing 365

APPLICATION to file document Defendants' Application To File Unredacted Reply Brief Regarding Response To Class Counsel's Billing Records Under Seal under seal filed by Defendant Warner Chappell Music Inc. (Attachments: # 1 Proposed Order, # 2 Redacted Document Defendants [Redacted] Reply Brief Regarding Response To Class Counsels Billing Records, # 3 Declaration of Kelly Klaus in Support of Application)(Klaus, Kelly)

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1 GLENN D. POMERANTZ (State Bar No. 112503) 2 KELLY M. KLAUS (State Bar No. 161091) 3 ADAM I. KAPLAN (State Bar No. 268182) 4 MUNGER, TOLLES & OLSON LLP 355 South Grand Avenue 5 Thirty-Fifth Floor Los Angeles, California 90071-1560 6 Telephone: (213) 683-9100 Facsimile: (213) 687-3702 7 Attorneys for Defendants 8 9 10 UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION 11 GOOD MORNING TO YOU PRODUCTIONS CORP.; et al., 12 Plaintiffs, 13 v. 14 WARNER/CHAPPELL MUSIC, INC., 15 et al., 16 Defendants. Lead Case No. CV 13-04460-GHK (MRWx) DEFENDANTS’ APPLICATION TO FILE UNREDACTED REPLY BRIEF REGARDING RESPONSE TO CLASS COUNSEL’S BILLING RECORDS UNDER SEAL Courtroom: Judge: 650 Hon. George H. King, 17 18 19 20 21 22 23 24 25 26 27 28 DEFS.’ APPLICATION TO FILE UNDER SEAL CASE NO. CV 13-04460-GHK 1 TO THE COURT AND ALL PARTIES AND THEIR RESPECTIVE 2 COUNSEL OF RECORD: 3 Pursuant to Central District of California Civil Local Rule 79-5.1; the Court’s 4 Order of June 10, 2016 (Dkt. No. 334), which required Class Counsel to file under 5 seal their billing records in this matter; and the Court’s Order of June 27, 2016 6 Order (Dkt. No. 347), which set forth the briefing schedule for Defendants’ response 7 to Class Counsel’s billing records, Defendants Warner/Chappell Music, Inc. and 8 Summy-Birchard, Inc. (jointly, “Defendants”) hereby apply for an Order permitting 9 the following to be filed under seal: Defendants’ Unredacted Reply Brief Regarding 10 Response to Class Counsel’s Billing Records (“Unredacted Reply”). 11 The Unredacted Reply, like Defendants’ Opening Response Brief, quotes 12 from and describes Class Counsel’s billing records. Class Counsel filed those 13 records under seal pursuant to the Court’s June 10, 2016 Order. In light of the 14 Court’s prior sealing Orders, Defendants are compelled in the first instance to file 15 this application to file the Unredacted Reply under seal. Defendants will publicly 16 file a redacted version of their Reply Brief Regarding Response to Class Counsel’s 17 billing records. 18 Defendants respectfully submit, however, that good cause exists to require 19 Class Counsel to file a response that justifies the under seal filing of the Unredacted 20 Reply as well as the continued sealing of Defendants’ Unredacted Opening Brief on 21 this matter (Dkt. No. 361). Class Counsel publicly filed their Response to 22 Defendants’ Statement Regarding Class Counsel’s Billing Records (Dkt. No. 364) 23 even though that public filing quotes from, paraphrases, and analyzes the same 24 billing records that the Court gave Class Counsel permission to file under seal. 25 Class Counsel’s decision to file their brief publicly indicates that Class Counsel do 26 not believe that quotes from, paraphrasing of, or analyses of the contents of the 27 billing records are confidential. There is no good cause for Defendants’ opening 28 DEFS.’ APPLICATION TO FILE UNDER SEAL -1- CASE NO. CV 13-04460-GHK 1 and reply briefs to remain under seal and publicly available only in redacted form, 2 while the entirety of Class Counsel’s response brief appears in the public record. 3 4 DATED: July 19, 2016 MUNGER, TOLLES & OLSON LLP 5 6 7 8 By: /s/ Kelly M. Klaus KELLY M. KLAUS Attorneys for Defendants 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DEFS.’ APPLICATION TO FILE UNDER SEAL -2- CASE NO. CV 13-04460-GHK

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