Planned Parenthood Gulf Coast, Inc. et al v. Kliebert

MOTION for Leave to Seal Record and Substitute Paper

M.D. La.September 9, 2015

1 UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF LOUISIANA PLANNED PARENTHOOD GULF COAST, INC.; JANE DOE #1; JANE DOE #2; AND JANE DOE #3, Plaintiffs, v. KATHY KLIEBERT, SECRETARY, LOUISIANA DEPARTMENT OF HEALTH AND HOSPITALS, Defendant CIVIL ACTION NO. 3:15-cv-00565-JWD-SCR MOTION TO SEAL RECORD AND SUBSTITUTE PAPER NOW INTO COURT, through undersigned counsel, comes Defendant, Kathy Kliebert, in her official capacity as Secretary of the Louisiana Department of Health and Hospitals, which and who, with respect, moves that this Court seal the record of these proceedings in respect to CM/ECF Document 34-1, filed as Attachment 1 to Defendant’s Amended Opposition to Plaintiffs’ Motion for Temporary Restraining Order (Doc. 34) on September 8, 2015, pursuant to Fed. R. Civ. P. 5.2(e)(2). Defendant, with respect, further moves for leave of Court to substitute a redacted version for CM/ECF Document 34-1, attached hereto as Attachment 1, in order to provide a redacted version for the public record pursuant to Fed. R. Civ. P. 5.2(d). Good cause exists to seal the record with respect to CM/ECF Document 34-1 and to substitute a redacted version for the public record herein because the paper filed as Attachment 1 contains social-security numbers for individuals requiring protection under Fed. R. Civ. P. 5.2(a) and Local Civil Rule 5.2. Case 3:15-cv-00565-JWD-SCR Document 35 09/09/15 Page 1 of 3 2 Apart from redacted social-security numbers, the attached redacted version is identical to CM/ECF Document 34-1 in all other respects. Respectfully submitted on this 9th day of September, 2015, /s/ Ryan J. Romero Stephen R. Russo, T.A. (La. Bar Roll No. 23284) Kimberly L. Humbles (La. Bar Roll No. 24465) Kimberly L. Sullivan (La. Bar Roll No. 27540) Ryan J. Romero (La. Bar Roll No. 35987) Louisiana Department of Health & Hospitals 628 N. 4 th Street, Bienville Building P. O. Box 3836 Baton Rouge, LA 70821-3836 Telephone: (225) 342-1128 Facsimile: (225) 342-2232 Email: Stephen.Russo@LA.GOV Email: Kimberly.Humbles@LA.GOV Email: Kimberly.Sullivan@LA.GOV Email: Ryan.Romero@LA.GOV Attorneys for Defendant, Kathy Kliebert CERTIFICATE STATING THE POSITION OF THE OTHER PARTIES In accordance with Local Civil Rule 7(e), Defendant has attempted to obtain consent for the filing and granting of this motion from all parties having an interest to oppose prior to the filing of this motion with the Court. Counsel for Plaintiffs has indicated that Plaintiffs do not oppose and are in agreement with Defendant’s request to seal the un-redacted version of CM/ECF Document 34-1 and to substitute a redacted version of the filing for the public record. /s/ Ryan J. Romero Ryan J. Romero (La. Bar Roll No. 35987) Louisiana Department of Health & Hospitals Case 3:15-cv-00565-JWD-SCR Document 35 09/09/15 Page 2 of 3 3 CERTIFICATE OF SERVICE I hereby certify that on September 9, 2015, a copy of the foregoing Motion for Leave of Court to Amend Papers was filed electronically with the Clerk of Court using the CM/ECF system. Notice of this filing will be sent to all parties/counsel of record by operation of the Court’s electronic filing system. /s/ Ryan J. Romero Ryan J. Romero (La. Bar Roll No. 35987) Louisiana Department of Health & Hospitals Case 3:15-cv-00565-JWD-SCR Document 35 09/09/15 Page 3 of 3