Jane Doe v. Pennridge School District et al

MOTION to Seal EXHIBIT A OF ITS OPPOSITION TO DEFENDANTS MOTION TO DETERMINE THE SUFFICIENCY OF PLAINTIFFS RESPONSES TO REQUESTS FOR ADMISSIONS

E.D. Pa.June 26, 2018

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA JANE DOE, Plaintiff, v. PENNRIDGE SCHOOL DISTRICT, AND JACQUELINE A. RATTIGAN AND GINA DEBONA, in their official and individual capacities, Defendants. Case No. 2:17-cv-03570-TR PLAINTIFF’S MOTION TO SEAL EXHIBIT A OF ITS OPPOSITION TO DEFENDANTS’ MOTION TO DETERMINE THE SUFFICIENCY OF PLAINTIFF’S RESPONSES TO REQUESTS FOR ADMISSIONS Pursuant to Fed. R. Civ. P. 5.2(d) and L.R. Civ. P. 5.1.5 and the Stipulated Protective Order executed between the Parties on January 24, 2018, and entered by the Court on May 24, 2018, Plaintiff hereby requests permission to file under seal Exhibit A, Plaintiff’s Responses to Defendants’ Requests for Admission. Plaintiff has included a proposed order herewith. Dated: June 26, 2018 Respectfully submitted, BY: /s/ Matthew Graves Matthew Graves Michael Dee Aurelie Ercoli Katherine M. Ruffing DLA PIPER LLP (US) 500 Eighth Street, NW Washington, D.C. 20004 Telephone: 202-799-4469 E-mail: Matthew.Graves@dlapiper.com Michael.Dee@dlapiper.com Aurelie.Ercolie@dlapiper.com Katie.Ruffing@dlapiper.com Courtney G. Saleski (Bar No. 90207) Case 2:17-cv-03570-TR Document 52 Filed 06/26/18 Page 1 of 3 DLA PIPER LLP (US) One Liberty Place 1650 Mark Street, Suite 4900 Philadelphia, PA 19103-7300 Telephone: 215.656.2431 E-mail: Courtney.Saleski@dlapiper.com Neena Chaudhry Alexandra Brodsky NATIONAL WOMEN’S LAW CENTER 11 Dupont Circle, Suite 800 Washington, D.C. 20036 Telephone: 202-588-5180 Email: nchaudhry@nwlc.org abrodsky@nwlc.org Case 2:17-cv-03570-TR Document 52 Filed 06/26/18 Page 2 of 3 CERTIFICATE OF SERVICE I hereby certify that on the 26th day of June, 2018, I caused the foregoing Plaintiff’s Motion To Seal Exhibit A of Its Opposition To Defendants’ Motion to Determine the Sufficiency of Plaintiff’s Responses to Requests for Admission to be filed with the Clerk of Court of the United States District Court for the Eastern District of Pennsylvania using the ECF system, it is available for viewing and downloading from the ECF system, and a true and correct copy was served via ECF to all counsel of record registered with the ECF system. /s/ Matthew Graves Case 2:17-cv-03570-TR Document 52 Filed 06/26/18 Page 3 of 3