Opinion
2:21-cv-00693-JHC 2:20-cv-00424-JHC 2:22- cv-00965-JHC 2:22- cv-00965-JHC
07-31-2024
ELIZABETH DE COSTER, et al., on behalf of themselves and all other similarly situated, Plaintiffs, v. AMAZON.COM, INC., a Delaware corporation, Defendant. DEBORAH FRAME-WILSON, et al., on behalf of themselves and all other similarly situated, Plaintiffs, v. AMAZON.COM, INC., a Delaware corporation, Defendant. CHRISTOPHER BROWN, et al., on behalf of themselves and all others similarly situated, Plaintiffs, v. AMAZON.COM, INC., a Delaware corporation, Defendant.
STIPULATED MOTION AND ORDER REGARDING SEALING OF CLASS CERTIFICATION BRIEFING
The Parties have met and conferred with respect to the upcoming briefing on class certification, and anticipate that their briefs, declarations, exhibits, and expert reports will quote from and/or describe in detail a significant amount of information that has been designated as Confidential or Highly Confidential-Attorneys' Eyes Only by either a Party or Non-Party. Accordingly, in order to ensure that such materials are treated appropriately under the applicable protective order, and to reduce burdens on the Court, the Parties, and Non-Parties, pursuant to LCR 7(d)(1) and 10(g), the Parties and their respective counsel hereby stipulate and agree to the following procedure for filing and sealing in connection with the class certification briefing, subject to the Coiut's approval.
1. Pursuant to LCR 5(g)(2), each Party will provisionally file under seal its class certification briefs (including any opening, response, and reply briefs), expert declarations or reports, exhibits, and all other evidence and declarations on which that Party relies (collectively, “Class Certification Papers”) which contain material designated Confidential or Highly Confidential-Attorneys' Eyes Only by any Party or Non-Party.
2. Within four weeks of the filing of Plaintiffs' reply brief, pursuant to LCR 5(g), the Parties, and any necessaiy Non-Parties, will meet and confer and, as appropriate, file (1) public versions of their Class Certification Papers, with necessaiy redactions, and (2) corresponding motion(s) to seal pursuant to LCR 5(g)(3). The schedule for filing any such public versions of the Parties' Class Certification Papers and corresponding motion(s) to seal shall be as follows:
De Coster
Frame- Wilson
Brown
January 24, 2025
May 23, 2025
September 16, 2025
Filing of public versions of class certification papers and corresponding Motions to seal
February 21, 2025
June 20, 2025
October 14, 2025
See De Coster et al. v. Amazon.com, Inc., No. 2:21-cv-00693-JHC, ECF No. 160.
3. The Party or Non-Party seeking to maintain material under seal (or under redaction) shall be the movant for purposes of any such motion(s) to seal associated with the Parties' class certification briefing.
IT IS SO ORDERED.