Case3:00-cv-04599-TEH Document709 Filed08/17/12 Page1 of 2

1 BARBARA PARKER, City Attorney- State Bar #069722 RANDOLPH W. HALL, Chief Assistant City Attorney State Bar #080142 2 ROCIO V. FIERRO, Deputy City Attorney State Bar #139565 JAMILAH A. JEFFERSON, Deputy City Attorney State Bar #219027 3 One Frank H. Ogawa Plaza, 6th Floor Oakland, California 94612 4 Telephone: (510) 238-7686 Fax: (510) 238-6500 jjefferson@oaklandcityattorney.org 5 R20752/1009253 6 Attorneys for Defendant CITY OF OAKLAND 7 GREGORY M. FOX, State Bar No. 070876 8 Bertrand, Fox & Elliot The Waterfront Building 9 2749 Hyde Street San Francisco, CA 94109 10 Telephone: (415)353-0999 Fax: (415)353-0990 gfox@bfesf.com 11 Attorneys for Defendant 12 CITY OF OAKLAND 13 14 15 16 DELPHINE ALLEN, et al. 17 Plaintiffs, 18 v. 19 CITY OF OAKLAND, et al. 20 21 22 23 24 Defendant City of Oakland (City) respectfully moves the Court for an Order granting it Defendants. DEFENDANT CITY OF OAKLANDS ADMINISTRATIVE MOTION TO FILE UNDER SEAL THEIR MOTION [ON SHORTENED NOTICE] FOR EQUITABLE RELIEF REGARDING COMMUNICATION PROTOCOLS BETWEEN COURT MONITOR AND CITY PENDING REVIEW OF CONFIDENTIAL MATTER AND FOR A PROTECTIVE ORDER Case No. C 00-4599 TEH UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

25 leave to file a Motion for Equitable Relief Regarding Communication Protocols Between Court 26
EX PARTE MOTION -1C00-4599 TEH

Case3:00-cv-04599-TEH Document709 Filed08/17/12 Page2 of 2

1 Monitor and City Pending Review of Confidential Matter and for Protective Order under seal 2 pursuant to Local Rule 79-5 and General Order 62. 3 The City recently became aware of a highly sensitive personnel matter concerning

4 communications between the court monitor and city officers. The City is duty-bound to review this 5 matter and take appropriate action under the law and city policies. The Citys review will require 6 consideration of serious and potentially damaging allegations involving personnel matters that are 7 highly sensitive and confidential. Therefore, they should not be made part of the public court 8 record. 9 Sealing all documents in connection with the actual investigation and those in furtherance

10 of commencing the investigation is crucial. The Motion for Equitable Relief and Protective Order 11 is necessary prior to commencing the investigation and will include the specific details of the 12 highly sensitive allegations. Thus, the City respectfully requests leave to file the above mentioned 13 Motion for Equitable Relief and Protective Order under seal. 14 15 Dated: August 17, 2012 16 17 18 19 20 21 22 23 24 25 26
EX PARTE MOTION -2C00-4599 TEH

BARBARA J. PARKER, City Attorney RANDOLPH W. HALL, Chief Assistant City Attorney ROCIO V. FIERRO, Deputy City Attorney JAMILAH A. JEFFERSON, Deputy City Attorney By: /s/ Jamilah A. Jefferson Attorneys for Defendants CITY OF OAKLAND, et al.