NATIONAL VETERANS LEGAL SERVICES PROGRAM et al v. UNITED STATES OF AMERICA

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)

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
[e-mail]
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: [phone]
Facsimile: [phone]
GUPTA WESSLER PLLC
Deepak Gupta, Esq.
[e-mail]
Jonathan E. Taylor
[e-mail]
1735 20th Street, NW
Washington, DC 20009
Telephone: [phone]
Facsimile: [phone]
Counsel for Plaintiffs and the
Class

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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

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