PLAINTIFFS' REQUEST TO SEAL DOCUMENTS AND ORDER THEREON

JOHN A. MENDEZ, District Judge.

Plaintiffs MELINDA AVILA, GRETEL LORENZO, ALFREDO LORENZO, and JOSE LORENZO ("Plaintiffs") hereby move the Court, pursuant to Federal Rules of Civil Procedure (F.R.C.P.) 5.2 and Local Civil Rule 141, for an Order for Exhibits to Plaintiffs Evidentiary Appendix in Support of Opposition to the California Highway Patrol and Paul Varner's Motion for Summary Judgment (Dkt. No 62), Exhibits to Plaintiffs Evidentiary Appendix in Support of Plaintiffs Opposition to the County of Madera and Richard Gonzales' Motion for Summary Judgment (Dkt. No 64), and Exhibits A, K, L, Q, S, U, and W to the Declaration of Carolyn J. Frank In support of Motion for Partial Summary Judgment and/or Motion for Summary Adjudication (Dkt. Nos. 57-1; 57-11; 57-12; 57-17; 57-19; 57-21; 57-22) (the "exhibits") to be filed under seal with the Court.

Plaintiffs seeks relief from the court and request that the documents filed by Plaintiffs, specifically Exhibits 11 and 12 to Plaintiffs Evidentiary Appendix which are copies of police reports from the day of the incident and contain Plaintiffs date of birth be filed under seal. Further, Plaintiffs request that the documents filed by Ms. Frank for the County, which are County of Madera Claim for Damages forms and copies of police reports from the day of the incident, which contain Plaintiffs date of birth and social security numbers also be filed under seal.

The information contained in these exhibits violate Plaintiffs privacy and potentially expose them to privacy invasions, identity theft and scams. The disclosure of such information by Plaintiffs' Counsel was unintentional and Plaintiffs' Counsel therefore seeks the relief of court to remedy this disclosure. Plaintiffs are also concerned that the disclosure by Defense exposes Plaintiffs to elevated privacy concerns since it contains the name, date of birth, address and social security number of Plaintiffs. Plaintiffs seek relief of the Court to seal the identified exhibits.

Plaintiffs request that these documents be sealed until such records can be disposed of due to the privacy needs of Plaintiffs. The identity of those permitted to have access to this document shall be Court users and staff, Counsel for Plaintiffs and his office staff, Defense counsel Carolyn J. Frank and Catherine Woodbridge and their office staff, and all parties to this action.

Accordingly, Plaintiffs respectfully submit this Request to Seal Documents titled:

A proposed Order is attached hereto.

ORDER

Good cause appearing,

IT IS SO ORDERED that the Sentencing documents be filed under seal.