ProtectMarriage.com - Yes on 8, a Project of California Renewal et al v. Bowen et al

Filing 13

MOTION for PROTECTIVE ORDER and Leave to File Documents Under Seal by ProtectMarriage.com - Yes on 8, a Project of California Renewal, National Organization for Marriage California - Yes on 8, Sponsored by National Organization for Marriage, John Doe #1. (Attachments: #1 Proposed Order)(Chandler, Timothy) Modified on 1/13/2009 (Carlos, K).

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James Bopp, Jr. (Ind. State Bar No. 2838-84)* Barry A. Bostrom (Ind. State Bar No.11912-84)* Sarah E. Troupis (Wis. State Bar No. 1061515)* Scott F. Bieniek (Ill. State Bar No. 6295901)* BOPP, COLESON & BOSTROM 1 South Sixth Street Terre Haute, IN 47807-3510 Telephone: [phone] Facsimile: [phone] Counsel for All Plaintiffs Timothy D. Chandler (Cal. State Bar No. 234325)** ALLIANCE DEFENSE FUND 101 Parkshore Drive, Suite 100 Folsom, CA 95630 Telephone: [phone] Facsimile: [phone] Counsel for All Plaintiffs *Pro Hac Vice Application Pending ** Designated Counsel for Service United States District Court Eastern District of California Sacramento Division

ProtectMarriage.com, et al., v. Debra Bowen, et al., Defendants. Plaintiffs,

Case No. 2:09-CV-00058-MCE-DAD [PROPOSED] ORDER GRANTING PLAINTIFFS' MOTION FOR PROTECTIVE ORDER AND LEAVE TO FILE DOCUMENTS UNDER SEAL

[Proposed]Order Granting Plaintiffs' Motion for Protective Order and Leave to File Documents Under Seal

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Having considered Plaintiffs' Motion for Protective Order and Leave to File Documents Under Seal, the memorandums in support and opposition, the Court being fully advised, and good cause shown: IT IS HEREBY ORDERED that Plaintiffs' Motion for Protective Order and Leave to File Documents Under Seal is GRANTED; Plaintiffs have demonstrated that compelling justification exists to warrant the issuance of a protective order and for leave to file documents under seal. IT IS ORDERED that: (1) Plaintiffs ProtectMarriage.com, NOM-California, and the Class of Major Donors may file any declaration of any individual or organization that supported Proposition 8 under seal; (2) Plaintiffs ProtectMarriage.com, NOM-California, and the Class of Major Donors may redact any personal information from any and all filings not filed under seal that could be used to identify supporters of Proposition 8 or members of or donors to ProtectMarriage.com or NOM-California; (3) Plaintiffs ProtectMarriage.com, NOM-California, and the Class of Major Donors may file an additional unredacted copy under seal of any document that is redacted pursuant to FRCP 5.2(f), or in the alternative, may file a reference list under seal pursuant to FRCP 5.2(g); (4) Defendants, their agents, servants, employees, officials, or any other person acting in concert with them or on their behalf, are PROHIBITED from revealing the name of any individual that supported Proposition 8 or that is a member of or donor to ProtectMarriage.com or NOM-California.

[Proposed]Order Granting Plaintiffs' Motion for Protective Order and Leave to File Documents Under Seal

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SO ORDERED this ____ day of January, 2009.

______________________________ Hon. Morrison C. England, Jr. United States District Judge

[Proposed]Order Granting Plaintiffs' Motion for Protective Order and Leave to File Documents Under Seal

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