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Case 2::10-cv-09198,d%S -RNB Document 376 Filed 01/08/13 Page 1 of 3 Page ID #:17217 wae ,
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12 | Campy for Defendant Life Insurance
JONATHAN A. SHAPIRO (257199 WILMER Cae PICKERING HALE
Palo Alto, CA 94304 Tel: (229 858-610] Fax: (650) 858-6100 jonathan.shapiro@wilmerhale.com
ANDREA J. ROBINSON (PRO HAC VICE)
TIMOTHY J. PERLA (PRO HAC VICE)
JOEL A. FLEMING (281264) .
WILMER CUTLER PICKERING HALE a a
AND DORR LLP | © CLERK, US. DISTacT COURT |
iN rea ane s eae | oston, ’
Tel: (617) 526-6000 JAN - 8 2013
Fax: (617) 526-5000
andrea.robinson@wilmerhale.com ie to aa
timothy.perla@wilmerhale.com EPUTY
joel.fleming@wilmerhale.com ae as a \ cas
PARP IAI
Company of the Southwest
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UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA
os ‘ SOUTHERN DIVISION J@¥CE WALKER, KIM BRUCE CLASS ACTION H@WLETT, and MURIEL SPOONER, on behalf of themselves and all others CASE NO.: CV 10-9198 JVS (RNBx) similarl¥ situated, Formerly Case No.: 3:10-cv -04852 JSW Plaintiffs, from Northern District of California
vs. APPLICATION TO FILE UNDER
LIFE INSURANCE COMPANY OF THE | SEAL EXHIBIT A SUBMITTED WITH SOUTHWEST, a Texas corporation, and | PLAINTIFFS’ MOTION FOR CLASS DOES 1-50 CERTIFICATION OF NEW AND REMAINING CLAIMS RELATING Defendant. TO CURRENT BASIS POLICY VALUES
Judge: Hon. James V. Selna Date: February 4, 2013 Time: 1:30 p.m. Courtroom: 10C
F) ORICNAL
Case 2:10-cv-09198JYS -RNB Document 376 Filed 01/98/13 Page 2of3 Page ID i #:17218 ‘a ,
PLEASE TAKE NOTICE THAT pursuant to Civil Local Rule 79-5.1 and the Court’s Second Amended Protective Order in this action, Dkt. 102 at ¥ 10 (Sept. 26, 2011), Defendant Life Insurance Company of the Southwest (“LS W”) submits this application to the Court for an Order sealing Exhibit A to the Declaration of Brian P. Brosnahan in Support of Plaintiffs’ Motion for Class Certification of New and Remaining Claims Relating to Current Basis Policy Values on the grounds that it contains confidential information protected by the Protective Order.
Under Civil Local Rule 79-5.1, a party can request that documents be filed
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under seal by submitting a written application along with the documents sought to
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be filed under seal. The Court’s Second Amended Protective Order (the
“Protective Order’) requires that an application to seal be filed whenever any
papers are filed containing information and/or documents designated as i “CONFIDENTIAL” or “CONFIDENTIAL INFORMATION — PROTECTIVE
ORDER.” Dkt. 102 at 410. The specific grounds that apply are set forth below:
Brosnahan Declaration, Ex. A Exhibit A to the Declaration of Brian P. Brosnahan in Support of Plaintiffs’
Motion for Class Certification of New and Remaining Claims Relating to Current Basis Policy Values is an internal LSW memorandum. This document was designated as “CONFIDENTIAL.” The memorandum discusses the internal pricing strategies used by LSW in developing product guarantees, including profitability expectations and internal forecasting. This is confidential, non-public commercial information that, if disclosed to the general public or competitors of LSW could reasonably and in good faith be expected to result in prejudice or harm. For the foregoing reasons, LSW respectfully requests that the Court grant LSW’s application to the Court for an Order sealing Exhibit A to the Declaration
of Brian P. Brosnahan in Support of Plaintiffs’ Motion for Class Certification of
New and Remaining Claims Relating to Current Basis Policy Values.
]
Antivel IO INARNSNOAT 1
Case 2:10-cv-091 98,d¥js -RNB Document 376 Filed 074708/1 3 Page3of3 Page ID a #:17219 ‘ ;
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Dated: January 4, 2013
Antiveli® TAARNSNOT: I
Respectfully submitted,
WILMER CUTLER PICKERING HALE AND DORR LLP
By:
Attorneys for Defendant LIFE INSURANCE COMPANY OF THE SOUTHWEST