United States of America v. State of California et al

Filing 76

NOTICE of Request to Seal Document(s) pursuant to L.R. 141 by All Defendants. (Sherman, Lee)

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XAVIER BECERRA
Attorney General of California
THOMAS PATTERSON
Senior Assistant Attorney General
MICHAEL NEWMAN
SATOSHI YANAI
Supervising Deputy Attorneys General
CHRISTINE CHUANG
ANTHONY HAKL
CHEROKEE MELTON
LEE I. SHERMAN
Deputy Attorneys General
State Bar No. 272271
300 S. Spring Street
Los Angeles, CA 90013
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
Attorneys for Defendants
IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF CALIFORNIA

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Case No. 2:18-cv-00490-JAM-KJN

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THE UNITED STATES OF AMERICA,

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Plaintiff, NOTICE OF REQUEST TO SEAL
DOCUMENTS IN SUPPORT OF
DEFENDANTS’ OPPOSITION TO
v.
PLAINTIFF’S MOTION FOR
PRELIMINARY INJUNCTION
THE STATE OF CALIFORNIA; EDMUND
GERALD BROWN JR., Governor of
Date:
June 20, 2018
California, in his official capacity; and
Time:
10:00 a.m.
XAVIER BECERRA, Attorney General of
Courtroom: 6
California, in his official capacity,
Judge:
The Honorable John A.
Mendez
Defendants. Trial Date:
None set
Action Filed: March 6, 2018

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Notice of Req. to Seal Docs. in Supp. of Defs.’ Opp. to Pl.’s Mot. for Prelim. Inj.

(18-cv-00490-JAM-KJN)

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TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE THAT Defendants the State of California, Edmund Gerald

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Brown Jr., Governor of California, in his official capacity, and Xavier Becerra, Attorney General

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of California, in his official capacity (collectively, “Defendants”), hereby request this Court to

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seal documents submitted in support of Defendants’ Opposition to Plaintiff’s Motion for

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Preliminary Injunction, pursuant to Local Rule 141 and the Court’s Protective Order (ECF No.

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53). The documents that form the basis of Defendants’ request are (1) documents designated by

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Plaintiff under the Protective Order as confidential, including sensitive law enforcement

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information and/or personally identifiable information of third-party individuals; and (2)

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documents or portions of documents submitted by Defendants that contain confidential, sensitive

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law enforcement information. The Request to Seal Documents, proposed order, and all

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documents covered by the Request have been emailed to this Court’s proposed orders email box

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in accordance with Local Rule 141(b) and have been served on all parties.

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Dated: May 4, 2018

Respectfully Submitted,
XAVIER BECERRA
Attorney General of California

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/s/ Lee Sherman
Lee Sherman
Deputy Attorney General
Attorneys for Defendants

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Notice of Req. to Seal Docs. in Supp. of Defs.’ Opp. to Pl.’s Mot. for Prelim. Inj.

(18-cv-00490-JAM-KJN)

CERTIFICATE OF SERVICE
Case Name:

The United States of America v.
The State of California, et al.

No.

2:18-cv-00490-JAM-KJN

I hereby certify that on May 4, 2018, I electronically filed the following documents with the
Clerk of the Court by using the CM/ECF system:
NOTICE OF REQUEST TO SEAL DOCUMENTS IN SUPPORT OF DEFENDANTS’
OPPOSITION TO PLAINTIFF’S MOTION FOR PRELIMINARY INJUNCTION
I certify that all participants in the case are registered CM/ECF users and that service will be
accomplished by the CM/ECF system.
I declare under penalty of perjury under the laws of the State of California the foregoing is true
and correct and that this declaration was executed on May 4, 2018, at Sacramento, California.

Tursun Bier
Declarant
LA2018500720
13074047.docx

/s/ Tursun Bier
Signature