NEWDOW et al v. ROBERTS et al

Filing 70

Consent MOTION for Protective Order to Submit Child-Related Addresses (in First Amended Complaint) Under Seal by MICHAEL NEWDOW (Attachments: # 1 Text of Proposed Order Proposed Order Regarding Plantiffs' Assented-To Motion to Submit Child-Related Addersses (in First Amended Complaint) Under Seal)(Ritter, Robert)

NEWDOW et al v. ROBERTS et al

Doc. 70

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

MICHAEL NEWDOW, et al., Plaintiffs, v. HON. JOHN ROBERTS, JR., et al., Defendants. Civil Action No. 1:08-cv-02248-RBW

PLAINTIFFS' ASSENTED-TO MOTION TO SUBMIT CHILD-RELATED ADDRESSES (IN THE FIRST AMENDED COMPLAINT) UNDER SEAL

MICHAEL NEWDOW In pro per and pro hac vice PO BOX 233345 SACRAMENTO, CA 95823 [phone] [e-mail]

ROBERT V. RITTER DC BAR #414030 AHA ­ 1777 T STREET, NW WASHINGTON, DC 20009 [phone] [e-mail]

Dockets.Justia.com

In documents being filed concurrently with this document, Plaintiffs are seeking leave to file an Amended Complaint. Approximately 230 additional individuals are joining the original plaintiffs in the Amended Complaint. Of these, approximately forty are either minor children themselves, or are adults who currently are (or expect to be) parents with minor children during the pendency of this litigation. Because such minor children may be at risk of injury due to their participation in what is, for some, a very unpopular quest, Plaintiffs are herein seeking permission to submit their names and addresses (and/or those of their parents) under seal. Accompanying this Motion is a proposed Order. Because the pertinent arguments have already been presented to the Court in an earlier Motion for a Protective Order, Documents #30, and the Court has considered and ruled on that Motion, Document #36, a Memorandum in Support of this Motion is assumed to be unnecessary. (Plaintiffs will gladly provide such a memorandum, however, should the Court so prefer.) Pursuant to LCvR 7(k) and (m): (a) Consultation was obtained with Brad Rosenberg, opposing counsel for Defendants Hon. John Roberts, Jr., JCCIC, Senator Dianne Feinstein, AFIC, and Major General Richard Rowe. Mr. Rosenberg's address is: Brad Rosenberg USDOJ, Civil Division, Federal Programs Branch PO Box 883 Washington, DC 20044 Mr. Rosenberg consents to this Motion. (b) Consultation was obtained with E. Desmond Hogan, opposing counsel for Defendants PIC and Emmett Beliveau. Mr. Hogan's address is: E. Desmond Hogan Hogan & Hartson, LLP 555 Thirteenth St., NW Washington, DC 20004 Mr. Hogan consents to this Motion.

Newdow v. Roberts

Motion to Seal Addresses

March 10, 2009

(c) Consultation was obtained with Kevin Snider, opposing counsel for Defendants Rev. Rick Warren and Rev. Joseph Lowery. Mr. Snider's address is: Kevin Snider Pacific Justice Institute 9851 Horn Road, Suite 115 Sacramento, CA 95827 Mr. Snider consents to this Motion.

Respectfully submitted this 10th day of March, 2009, /s/ - Michael Newdow Michael Newdow In pro per and pro hac vice PO Box 233345 Sacramento, CA 95823 (916) 4 27-6669 [e-mail] /s/ - Robert V. Ritter Robert V. Ritter DC Bar #414030 AHA ­ 1777 T Street, NW Washington, DC 20009 [phone] [e-mail]

Newdow v. Roberts

Motion to Seal Addresses

March 10, 2009

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA Civil Action No. 1:08-cv-02248-RBW Newdow v. Roberts CERTIFICATE OF SERVICE I hereby certify that on March 10, 2009, I filed the following document: PLAINTIFFS' ASSENTED-TO MOTION TO SUBMIT CHILD-RELATED ADDRESSES (IN THE FIRST AMENDED COMPLAINT) UNDER SEAL electronically with the Clerk of the United States District Court for the District of Columbia, using the CM/ECF system. Accordingly, service will assumedly be made upon: Counsel for Defendants Roberts, JCCIC, Feinstein, AFIC and Rowe: Eric B. Beckenhauer [e-mail] Brad P. Rosenberg [e-mail] Counsel for Defendants PIC and Beliveau: Desmond Hogan [e-mail] Craig Alan Hoover [e-mail] Dominic F. Perella [e-mail] Counsel for Defendants Warren and Lowery: J. Stephen Simms [e-mail] Kevin E. Snider [e-mail]

/s/ - Robert V. Ritter ROBERT V. RITTER DC BAR #414030 AHA ­ 1777 T STREET, NW WASHINGTON, DC 20009 [phone] [e-mail]

Newdow v. Roberts

Motion to Seal Addresses

March 10, 2009

Certificate of Service