Cornell v. SoundGarden

1 THE HONORABLE ROBERT S. LASNIK UNITED STATES DISTRICT COURT 7 WESTERN DISTRICT OF WASHINGTON AT SEATTLE || VICKY CORNELL, individually, and in No. 2:21-cv-00192-RSL her capacity as the Personal Representative || of the Estate of Christopher John Cornell a/k/a Chris Cornell, 11 STIPULATED MOTION AND ORDER Plaintiffs, GRANTING MOTION TO SEAL 12 DOCKET NOS. 1-2, 3-2, 3-3, and 3-4 v. SOUNDGARDEN, a purported || Washington General Partnership; KIM A.

THAYIL; MATT D. CAMERON; || HUNTER BENEDICT SHEPHERD; SOUNDGARDEN RECORDINGS, LLC, || a Delaware limited liability company; STAGE MUTHA FAKIR, INC., a || Washington corporation, and SG PRODUCTIONS, INC., a Washington || corporation, LOUD LOVE MUSIC, an entity of unknown origin, Defendants.

22 The Parties in the above-captioned case respectfully request that Docket Nos. 1-2, 3-2, 3- || 3, and 3-4 remain under seal. Docket Nos. 1-2, 3-2, 3-3, and 3-4 were filed on the public docket || and include personal information of several Defendants. To preserve the confidentiality of this || information, the Parties respectfully request that the Court maintain Docket Nos. 1-2, 3-2, 3-3, and || 3-4 under seal.

Perkins Coie LLP STIPULATED MOTION TO SEAL 1201 Third Avenue, Suite 4900 DOCKET NOS. 1.2, 3-2, 3-3, AND 3-4 -1 Seattle, WA 98101-3099 1 This Court seals documents upon a showing of “good cause”—applying a less demanding || standard to documents that are “tangentially related to the merits of a case.” Olympic Air, Inc. v. || Helicopter Tech. Co., No. C17-1257-RSL, 2020 WL 6381810, at *5 (W.D. Wash. Oct. 30, 2020) || (quoting Ctr. for Auto Safety v. Chrysler Grp., 809 F.3d 1092, 1098-1101 (9th Cir. 2016)); see || W.D. Wash. Local Civ. R. 5(g)(2). Under Rule 26, there is good cause where sealing a document || is necessary “to protect a party or person from annoyance, embarrassment, oppression, or undue || burden or expense.” Fed. R. Civ. P. 26(c)(1).

8 Here, there is good cause to maintain the documents at issue under seal, which were || originally filed unsealed and unredacted, and subsequently sealed by the Court. These documents 10 are merely summonses, are unrelated to the merits of the case, and contain unredacted personal || identifying information about several Defendants, the disclosure of which serves no public interest || and would likely result in an invasion of privacy. See, e.g., Wagafe v. Trump, No. C17-94-RAJ, || 2019 WL 4673334, at *2 (W.D. Wash. May 28, 2019) (finding good cause to seal where || documents “contain[ing] sensitive personal informational . . . the public release of which could || cause harm”); Miller v. Boys & Girls Clubs of Snohomish Cty., No. C15-2027-JCC, 2017 WL 16 || 897811, at *10 (W.D. Wash. Mar. 7, 2017) (granting stipulated motion to seal where the || documents at issue “contain[ed] private medical and personal information about Plaintiff”); Troy || v. Kehe Food Distribs., Inc., No. CO9-0785-JLR, 2010 WL 11566229, at *1 (W.D. Wash. Sept.

19 |} 23, 2010) (granting motion to seal exhibits that “contain[ed] personal information about potential || class members”). That the Defendants are public figures only heightens the privacy concerns and 21 risk of harm.

22 For the foregoing reasons, the Parties respectfully request that this Court grant this 23 stipulated motion to maintain Docket Nos. 1-2, 3-2, 3-3, and 3-4 under seal.

Perkins Coie LLP STIPULATED MOTION TO SEAL seattle, WA 98 101.3099. ! | ITISSO ORDERED: DATED this 25th day of February, 2021.

Af ° MICHELLE L. PETERSON 6 United States Magistrate Judge had Av vate ‘Sui 4900 STIPULATED MOTION TOSEAL □ seattle, WA 98101-3099 1 Presented by: By: s/ William C. Rava By: s/Paul H. Beattie 3 William C. Rava #29948 Paul H. Beattie, WSBA # 30277 Alison R. Caditz #51530 Gravis Law 4 Perkins Coie LLP 7920 SE Stellar Way 1201 Third Avenue, Suite 4900 Snoqualmie, WA 98065 5 Seattle, WA 98101-3099 Telephone: 206.696.9095 Telephone: 206.359.8000 Email: pbeattie@ gravislaw.com 6 Email: WRava@ perkinscoie.com Email: ACaditz @ perkinscoie.com Gabriel G. Gregg (pro hac vice to be 7 submitted) Martin D. Singer (pro hac vice to be Matthew H. Poppe (pro hac vice to be 8 submitted) submitted) David Binder Jonelis (pro hac vice to be Rimon PC 9 submitted) 800 Oak Grove Ave, Suite 250 Lavely & Singer Menlo Park, CA 94025 10 2049 Century Park East, Suite 2400 Telephone: 408.669.5354 Los Angeles, CA 90067 Email: gabriel.gregg @rimonlaw.com 11 Telephone: 310.556.3501 Email: Email: djonelis @ lavelysinger.com [email protected] 12 Email: mdsinger@ lavelysinger.com Attorneys for Defendants 13 James George Sammataro (pro hac vice to be submitted) 14 Pryor Cashman LLP South Biscayne Blvd., Suite 2700 15 Miami, FL 33131 Telephone: 786.582.3010 16 Email: jsammataro @ pryorcashman.com 17 Attorneys for Plaintiffs Perkins Coie LLP 1201 Third Avenue, Suite 4900 STIPULATED MOTION TO SEAL RACVET NANG 159 2522 ANT24 4 Seattle, WA 98101-3099 1 CERTIFICATE OF SERVICE 2 I hereby certify under penalty of perjury that this on the date mentioned below, a copy of the foregoing document was filed electronically. I understand that notice of this filing was sent to all || parties by operation of the Court’s electronic filing system. Parties may access this filing through the || Court’s system.

6 DATED: February 23, 2021.

3 Lacie Mahe Jackie Slavik Perkins Coie LLP CERTIFICATE OF SERVICE — 1 1201 Third Avenue, Suite 4900 Seattle, WA 98101-3099