IN RE: IN THE MATTER OF THE APPLICATION OF THE NEW YORK TIMES COMPANY FOR ACCESS TO CERTAIN SEALED COURT RECORDS

Filing 8

MOTION to Seal Declaration and for Permission to File Declaration in Redacted Form re 7 MOTION for Order Setting Date by Which Government Shall File Opposition to Motion for Public Access to Certain Sealed Records re 1 MOTION MOTION FOR PUBLIC ACCESS TO CERTAIN SEALED COURT RECORDS MOTION for Order Setting Date by Which Government Shall File Opposition to Motion for Public Access to Certain Sealed Records re 1 MOTION MOTION FOR PUBLIC ACCESS TO CERTAIN SEALED COURT RECORDS by LOS ANGELES TIMES COMMUNICATIONS LLC, THE NEW YORK TIMES COMPANY (Attachments: # 1 Exhibit, # 2 Text of Proposed Order)(Bead, Jeanette)

IN RE: IN THE MATTER OF THE APPLICATION OF THE NEW YORK TIMES COMPANY FO...TAIN SEALED COURT RECORDS. 8 Doc

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE APPLICATION OF THE NEW YORK TIMES COMPANY FOR ACCESS TO CERTAIN SEALED COURT RECORDS

Misc. Action No. 1:08-mc-00576-RCL

UNOPPOSED MOTION TO SEAL DECLARATION AND FOR PERMISSION TO FILE DECLARATION IN REDACTED FORM The New York Times Company and Los Angeles Times Communications LLC (together, "Movants"), hereby respectfully move the Court for an Order sealing the Declaration of Jeanette Melendez Bead. In support of this Motion, Movants aver as follows: 1. On September 29, 2008, Movants filed a Motion for Order Setting Date by Which

the Government Shall File Opposition to Motion for Public Access to Certain Sealed Records. 2. The Declaration of Jeanette Melendez Bead (the "Bead Declaration"), which was

submitted with the Motion, inadvertently included the personal cell phone number of Rachel Carlson Lieber, the Assistant United States Attorney representing the government in this matter. 3. Ms. Lieber's personal cell phone number is not essential to the motion, and

Movants therefore request that they be permitted to substitute a new version of the Bead Declaration with Ms. Lieber's personal cell phone number redacted. A copy of the new version is attached hereto as Exhibit A. 4. this Motion. Movants are authorized to inform the Court that the government does not oppose

Dockets.Justia.com

WHEREFORE, for the reasons stated herein Movants respectfully request that the Court grant their motion and enter an Order sealing the Declaration of Jeanette Melendez Bead and permitting them to substitute the Bead Declaration with the redacted Declaration attached hereto. Dated: September 29, 2008 Respectfully submitted, LEVINE SULLIVAN KOCH & SCHULZ, L.L.P.

By:

/s/ Jeanette M. Bead David A. Schulz, DC Bar No. 459197 Jeanette M. Bead, DC Bar No. 480539

1050 Seventeenth Street, NW Suite 800 Washington, DC 20036-5514 Phone [phone] Fax [phone] Of Counsel: David E. McCraw The New York Times Company 620 Eighth Avenue 18th Floor New York, NY 10018 Karlene W. Goller Los Angeles Times Communications LLC 202 West First Street Third Floor Los Angeles, California 90012

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