Respondents know this case is high profile and, indeed, have taken significant steps to publicize their involvement in it on both their firm’s website and in social media. See, e.g., http://boothsweet.com/blog/news/happy-halloween-to-prenda-law-the-nightmare- continues/ (last visited on May 12, 2014) (publicizing their efforts in this case).2 In high profile cases, violations of Rule 5.2 and its counterparts threaten to inflict much higher harm and call for more extreme care. Here, Respondents cavalierly admit that they did not even bother to review the offending exhibit before filing, and instead based their redaction certification on an “erroneous assumption.

Overall, the patient is very much improved from a functional status compared to before her surgery in May of 2004. Michael B. Noone, M.D. MB~~~'/ cc: Dr. Kristin Dolling Dr. Lazar POCZTOWSKID_ILLUR_MDR00023 Case 2:12-cv-01470 Document 62-10 Filed 07/08/16 Page 3 of 3 PageID #: 695 EXHIBIT K Redacted pursuant to Fed. R. Civ. P. 5.2 and PTO 11 Case 2:12-cv-01470 Document 62-11 Filed 07/08/16 Page 1 of 30 PageID #: 696 PRIVILEGED AND HIGHLY CONFIDENTIAL INFORMATION Patient: Debra Pocztowski Records Provider: Plaintiff Fact Sheet Records Obtained: 01/21/2016 231962.026.

The Petition fails to justify any such expense for an unproven loss. See Matthys v. Green Tree Serv., LLC (In re Matthys), No. 09-16585-AJM-13, 2010 Bankr. LEXIS 1765 (Bankr. S.D. Ind. May 26, 2010) (dismissing claim based on violation of Fed. R. Civ. P. 5.2 and related rules); accord Killian v. Green Tree Servicing, LLC (In re Killian), No. 05-14629-HB, 2009 Bankr. LEXIS 2030 (Bankr. D.S.C. July 23, 2009). 12 Case 3:12-cv-00889-DRH-SCW Document 176 Filed 05/21/14 Page 12 of 15 Page ID #4006 Even if Hansmeier did require identity theft protection, he need not incur such great expense.13 According to Consumer Reports, “do-it-yourself safeguards are just as effective as paid services.”

(See, e.g., Doc. 21-1 at pp. 11, 33, and 38).1 4. The undersigned counsel for Defendant has conferred with Plaintiff’s counsel regarding Plaintiff’s filing of his Initial Disclosures and the documents referenced therein, as well as the requirements of Federal Rules of Civil Procedure 5(d)(1) and 5.2(a), and Plaintiff’s counsel has consented to and does not oppose the grant of this motion to strike Plaintiff’s Initial Disclosures and the documents he filed on September 29, 2017 (Docs. 21 and 21-1). 5. No party will be prejudiced by the grant of this motion.

/ / / / / / / / / / / / / / / / / / / / / Case 2:16-cv-02597-APG-CWH Document 68 Filed 10/24/17 Page 3 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Page 4 of 4 Based upon the foregoing, the DaVita Parties respectfully request that this Court issue an order redacting 12:17 through 13:28 of the Motion for Temporary Restraining Order and Preliminary Injunction and sealing Exhibits F through M thereto. See Fed. R. Civ. P. 5.2(d); Selling Source, LLC, No. 2:09-CV-01491-JCM, 2011 WL 1630338, at *6. DATED this 24th day of October, 2017.

Deutsche Solar’s Motion satisfies these requirements. First, there are two authorities for sealing the Exhibits: Fed. R. Civ. P. 5.2(d) and the Protective Order (R. 28 at Page ID # 274-75, ¶ 12(a)). Second, the Motion identifies the Exhibits to be sealed in full or in part.

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.

CONCLUSION Plaintiffs Jane Doe # 1 and Jane Doe # 2 respectfully request that the Court grant this motion and permit them to proceed under pseudonyms. Plaintiffs additionally request that, pursuant to Federal Rule of Civil Procedure 5.2(e), this Court orders all parties to use Plaintiff Jane Doe # 1’s and Jane Doe # 2’s pseudonyms in all documents filed in this action. Dated: June 23, 2015 By: /s/ Harold J. McElhinny Harold J. McElhinny* Kevin M. Coles* Elizabeth Balassone* MORRISON & FOERSTER LLP 425 Market Street San Francisco, CA 94105-2482 Telephone: (415) 268-7000 Facsimile: (415) 268-7522 Email: HMcElhinny@mofo.com Email: KColes@mofo.com Colette Reiner Mayer* MORRISON & FOERSTER LLP 755 Page Mill Road Palo Alto, CA 94304-1018 Telephone: (650) 813-5600 Facsimile: (650) 494-0792 Email: CRMayer@mofo.com Louise C. Stoupe* Pieter S. de Ganon* MORRISON & FOERSTER LLP Shin-Marunouchi Building, 29th Floor 5-1, Marunouchi 1-Chome Tokyo, Chiyoda-ku 100-6529, Japan Telephone: +81-3-3214-6522 Facsimile: +81-3-3214-6512 Email: LStoupe@mofo.com Email: PdeGanon@mofo.com MOTION TO PROCEED UNDER PSEUDONYMS AND FOR PROTECTIVE ORDER CASE NO. 4:15-CV-00250-DCB 9 sf-35

Exhibit 31 was created over the course of Plaintiffs’ investigation in this matter, and was generated by using the PII of a minor. Pursuant to Federal Rule of Civil Procedure 5.2(a), Plaintiffs have redacted all references to the known minor’s name from Exhibit 31, but also seek leave to file under seal all other information that is personally identifying, including the minor’s Facebook.com UserID, user name, and personal pictures. Documents and Exhibits Marked as Confidential by comScore 5.

2(e) empowers a court to enter an order requiring the redaction of information or to limit or prohibit a nonparty' s remote electronic access to a document filed with the court. See Fed. R. Civ. P. 5.2(e). The Confidential Discovery Material discussed at the July 18 Hearing was designated as such months - and in some instances years - ago, and remain so.