[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)],
Plaintiff(s),
v.
[Defendant(s)],
Defendant(s).
|
Case No.
STIPULATION AND REQUEST FOR COURT ORDER AUTHORIZING FILING OF DOCUMENTS UNDER SEAL
[Optional: NOT OPPOSED]
Assigned to the Hon. [Judge]
|
Pursuant to [local civil rule], the undersigned parties stipulate that the Court may enter an Order authorizing the document(s) lodged herewith to be filed under seal. As required by [local civil rule], a complete, unredacted copy of the document(s) for which permission to file under seal is requested has been lodged with the court clerk [electronically/in paper form in a secured envelope].
[OPTIONAL: In addition, pursuant to [local civil rule], a publicly accessible version of the document(s) is attached hereto as Exhibit A, redacting only those portions of the document(s) that are the subject of this Stipulation.]
This Stipulation and request for an Order authorizing filing under seal is made upon the grounds and for the reasons that:
(1) an overriding interest exists that supports filing the [lodged document(s)/portions of the lodged document(s)] under seal and overcomes the public’s right of access;
(2) there is a substantial probability of prejudice to [identification of whether prejudice is to person filing the motion or another person] if the [lodged document(s)/portions of document(s)] are not filed under seal;
(3) the proposed restriction on public access is no greater than necessary to preserve the confidentiality of information subject to the overriding interest;
(4) no reasonable, less restrictive alternative exists to preserve the confidentiality of the information.
[Statement of whether stipulation is opposed or unopposed, and if opposed, identity of party opposing stipulation and statement that stipulation is accompanied by a good faith consultation certificate in accordance with local rule].
As required by [local civil rule], [local civil rule], the facts and legal authority justifying this sealing request, and establishing why the request satisfies the requirements of [local civil rule], are as follows:
[Clear statement of the facts and legal authority justifying sealing].
Dated this [Day] of [Month], [Year].
By
[Name of 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]
/s/[Attorney] |
