Filing 40

Consent MOTION for Protective Order by ALLIANCE FOR JUSTICE, NATIONAL CONSUMER LAW CENTER, NATIONAL VETERANS LEGAL SERVICES PROGRAM (Attachments: #1 Text of Proposed Order)(Narwold, William)

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Case 1:16-cv-00745-ESH Document 40 Filed 03/31/17 Page 1 of 3 IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA NATIONAL VETERANS LEGAL SERVICES PROGRAM, NATIONAL CONSUMER LAW CENTER, and ALLIANCE FOR JUSTICE, for themselves and all others similarly situated, Plaintiffs, Civil Action No. 16-745 ESH v. UNITED STATES OF AMERICA, Defendant. CONSENT MOTION FOR ENTRY OF STIPULATED PROTECTIVE ORDER The parties have conferred, and believe that a Protective Order is necessary to protect the privacy of PACER account holders, whose information must be provided to the class administrator for purposes of providing notice to the class. Protection of class member data constitutes sufficient good cause to justify limiting the use of information obtained for purposes of providing class notice, and to justify the entry of a protective order. Fed. R. Civ. P. 26(c); Aguirre v. Shapiro, 263 F.R.D. 26, 29 (D.D.C. 2009). The parties have agreed on the attached Stipulated Protective Order to apply to the production of class member data for purposes of class notice, and Defendant has consented to the filing of this Motion. Therefore, Plaintiffs respectfully request that the Court grant the Consent Motion and enter the attached Stipulated Protective Order. By: /s/ William H. Narwold MOTLEY RICE LLC William H. Narwold DC Bar No. 502352 Case 1:16-cv-00745-ESH Document 40 Filed 03/31/17 Page 2 of 3 One Corporate Center 20 Church Street, 17th Floor Hartford, CT 06103 Telephone: (860) 882-1676 Facsimile: (860) 882-1682 GUPTA WESSLER PLLC Deepak Gupta, Esq. Jonathan E. Taylor 1735 20th Street, NW Washington, DC 20009 Telephone: (202) 888-1741 Facsimile: (202) 888-7792 Counsel for Plaintiffs and the Class 2 Case 1:16-cv-00745-ESH Document 40 Filed 03/31/17 Page 3 of 3 CERTIFICATE OF SERVICE I, William H. Narwold, declare that I am over the age of eighteen (18) and not a party to the entitled action. I am a principal of the law firm MOTLEY RICE LLC, and my office is located at One Corporate Center, 20 Church Street, 17th Floor, Hartford, CT 06103. On March 31, 2017, I caused to be filed the following in the above-captioned case: Consent Motion For Entry Of Stipulated Protective Order with the Clerk of Court using the Official Court Electronic Document Filing System, which served copies on all interested parties registered for electronic filing. I declare under penalty of perjury that the foregoing is true and correct. Dated: March 31, 2017 Respectfully submitted, By: /s/ William H. Narwold William H. Narwold MOTLEY RICE LLC 3

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