Académique Documents
Professionnel Documents
Culture Documents
)
)
)
)
)
)
)
)
)
Under Local Rule 83-13.05(A)(1), [u]pon a showing of good cause the Court
may order that documents filed in a civil case be received and maintained by the Clerk under
711557439
seal. Additionally, paragraph 6 of the Protective Order in this case provides that third parties
shall be entitled to designate documents as Confidential or Confidential Attorneys Eyes
Only and that documents designated as such shall not be disclosed publicly and shall only be
disclosed to specific individuals (including the Court and its personnel) as set forth in paragraph
4 thereto. (Dkt. 38). The Protective Order also grants leave to make filings of confidential
documents under seal in compliance with Local Rule 83- 13.05(A). (Id. at 12.).
2.
The third party that produced Exhibits A, B and E in late September 2014,
Respectfully submitted,
Washington, DC 20006
Telephone: (202) 263-3227
Facsimile: (202) 263-5227
czarlenga@mayerbrown.com
Richard M. Assmus (pro hac vice)
Kristine M. Young (pro hac vice)
MAYER BROWN LLP
71 South Wacker Drive
Chicago, Illinois 60606
Telephone: (312) 782-0600
Facsimile: (312) 701-7711
rassmus@mayerbrown.com
kyoung@mayerbrown.com
David A. Roodman, 38109MO
BRYAN CAVE LLP
211 North Broadway #3600
St. Louis, Missouri 63102
Telephone: (314) 259-2000
Facsimile: (314) 259-2020
daroodman@bryancave.com
3
711557439
CERTIFICATE OF SERVICE
The undersigned hereby certifies that he caused a true and correct copy of the foregoing
Motion for Leave to File Motion to Compel and Exhibits A, B and E Thereto Under Seal and
Memorandum in Support Thereof to be served on all counsel of record who are deemed to have
consented to electronic service on this day of October 10, 2014 via the Courts CM/ECF system
and via electronic mail.
711557439