Sacramento E.D.M., Inc., et al. v. Hynes Aviation Industries, Inc., et al.

Filing 69

STIPULATION and ORDER to seal exhibit signed by Chief Judge Morrison C. England, Jr on 8/22/14. Document sealed. Replacement document shall be redacted to eliminate private information. (Manzer, C)

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Thomas W. Barth, SBN 154075

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431 I Street, Suite 201
Sacramento, California 95814
Telephone: [phone]
Facsimile: [phone]

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BARTH DALY LLP

Attorneys for HYNES AVIATION
INDUSTRIES, INC., HYNES CHILDREN
TF LIMITED and MICHAEL HYNES

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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B ARTH D ALY

LLP
ATTORNEYS AT LAW
SACRAM ENTO, CALIFORNIA

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SACRAMENTO E.D.M., INC., a California
corporation; DAN FOLK, an individual,
Plaintiffs,

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v.

Case No. 2:13-CV-00288-MCE-KJN
STIPULATION AND ORDER TO SEAL
EXHIBIT AND REPLACE WITH
REDACTED EXHIBIT

HYNES AVIATION INDUSTRIES, INC.
dba HYNES AVIATION SERVICES, an
Oklahoma corporation; HYNES
CHILDREN TF LIMITED, a business
entity, form unknown; MICHAEL K.
HYNES, an individual; and DOES 1
through 50, inclusive,
Defendants.

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TO THE COURT AND ALL PARTIES AND THEIR ATTORNEYS OF RECORD:

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NOTICE IS HEREBY GIVEN that the parties hereby stipulate by and through their

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respective attorneys that Exhibit 1 attached to Exhibit A to the Declaration of Thomas W. Barth

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in Support of Motion for Leave to File Counterclaim and for Amendment of Pretrial Scheduling

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Order (Pages 9 of 50 through 29 of 50, Document No. 54-1 of the Court Docket) filed in this

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action on July 21, 2014 be sealed and replaced with a completely redacted copy per agreement of

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counsel. Accordingly, the parties request the Court seal the currently filed Exhibit 1 and permit a

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///
{00013334}
STIPULATION AND [PROPOSED] ORDER TO SEAL EXHIBIT

-1[2:13-CV-00288-MCE-KJN]

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properly redacted copy be filed in its place. Attached to this stipulation is the proposed Exhibit 1,

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with complete, appropriate redaction.

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Respectfully submitted,
Dated: August 8, 2014.

BARTH DALY LLP

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By

/s/Thomas W. Barth
THOMAS W. BARTH
Attorneys for Defendants HYNES AVIATION
INDUSTRIES, INC., HYNES CHILDREN TF LIMITED
and MICHAEL HYNES

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FOOS GAVIN LAW FIRM, P.C.

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B ARTH D ALY

LLP
ATTORNEYS AT LAW
SACRAM ENTO, CALIFORNIA

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Dated: August 8, 2014.

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By

/s/Sean Gavin
SEAN GAVIN
Attorneys for Plaintiffs SACRAMENTO
E.D.M. INC., and DAN FOLK

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ORDER

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Good Cause Appearing, IT IS HEREBY ORDERED Exhibit 1 to Exhibit A of the

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Declaration of Thomas W. Barth in Support of Motion for Leave to File Counterclaim and for

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Amendment of Pretrial Scheduling Order (Pages 9 of 50 through 29 of 50, Document No. 54-1 of

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the Court Docket) be SEALED and the replacement Exhibit 1 (ECF No. 62 at 4-23), redacted to

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eliminate private information, also be FILED.

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IT IS SO ORDERED.
Dated: August 22, 2014

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-2-

{00013334}
STIPULATION AND ORDER TO SEAL EXHIBIT

[2:13-CV-00288-MCE-KJN]