[Firm Name]

[Firm Address]

[Firm Phone Number]

[Firm Fax]

[Firm Email]

[Attorney Name and Bar Number]

Attorney for Plaintiff(s)/Defendant(s)


[Trial Court System], [County]


[Plaintiff Name(s)],










Case No.





Assigned to the Hon. [Judge]




PLEASE TAKE NOTICE that, pursuant to [local civil rule], [name of submitting party] seeks to publicly disclose the contents of the document(s) lodged herewith [in a court filing/deposition/other]. The document(s) was produced by [identification of party or person producing document] pursuant to a [protective order/confidentiality agreement] that requires the document to be filed under seal.

As required by [local civil rule], [name of submitting party] has conferred in good faith with [name of producing party or person] in an attempt to reach an agreement regarding whether the content of the document(s) satisfies [local civil rule]’s requirements for filing under seal. No agreement has been reached. A [local civil rule] good faith consultation certificate is attached. The nature of the dispute and [name of submitting party]’s position is summarized below.

[Summary of dispute and specification of submitting party’s position].

Pursuant to [local civil rule], within [# of days in accordance with local rule] days after service of this Notice, [name of producing party or person] must file and serve a notice withdrawing its confidentiality designation and allowing the document(s) to be publicly filed, or a motion to seal and supporting memorandum under [local civil rule]. If no such notice or motion is filed, the Court may enter an order making the document part of the public record.

Dated this [Day] of [Month], [Year].



[Name of submitting party’s Attorney]

[Firm Name]

[Firm Address]

Attorney for Plaintiff(s)/Defendant(s)








On [Date], undersigned:


[Filed/E-filed] the original;


[Mailed/Emailed/Hand Delivered] a copy to:

·      [Opposing Counsel]