[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.




[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].



[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]