Professional Documents
Culture Documents
A
.f Case 0:15-cv-60581-WPD Document 9 Entered on FLSD Docket 03/24/2015 Page 1 of 5
;
sxc
k'
FILED b
UN ITED STATES D ISTRICT COU RT
SOU TH ERN D ISTRICT OF FLO RIDA
FO RT LAU D ERD A LE D IV ISION
D.C.
MAq 2 3 2015
STEVEN M LAaIMORE
CLERKU b DIST CT
s o ofFLA - M I
AMI
VS.
Plaintiff,BarbaraBnmnerPereira(ttM ovanf')movestoFileDocumentsUnderSealand
forProted ion,and in supportthereto w ould show the Courtas follow s:
Foundation.M ovanttiled suitanonym ously using the nam eJaneDoe,with a11referencesto her
and to her fam ily m em bersbeing anonym ous.
2.
M ovanthas attached her Aftidavitand its Exhibits to this M otion for the Court's
in cam era review and w hich she requests be filed under sealas an Exhibitto her O liginalClass
A ction Com plaint against Texas A& M University 12tll M an Foundation. See Exhibit 1 --
com pete unhindered for thatposition. Further,M ovantavers thatshe is aw are thatothers have
alleged that they w ere threatened by a Foundation ofticial and that such claim s, if true, are
consistentwith herperception ofthe culture atthe Foundation. See Exhibit 1,paragraph 7. See
also OriginalClass A ction Com plaint, A ffidavitofHerlry H .Holubec,Jr., Exhibit8,
'A ftidavitof
M ovant requests that her A ffidavit and its Exhibits and the Court's Order
disposing ofthis m otion be tiled with the C lerk ofCourtundersealand thatthe Courtorder that
the C lerk of Courtnot diselose the eontents ofthis m otion, the Court'sOrderand the Aftidavit
and its Exhibits to any pel-son or entity, exceptto the Courtand its in-eham bers staff, except as
furthersetforth below.
M ovant further requests that a copy of the Order disposing of this M otion be
provided to counselforthe M ovant/plaintiff.
6.
M ovant further requests thatcopies ofthe O rder disposing of this m otion and of
specitically and directly involved in this litigation and who have a need to know of their
existence and content.
M ovant further requests that the Court order that a11 persons referred to in
and EEJOH N D OE
the prosecution ordefense ofthism atter, and thatallsuch persons shallrefer to the Plaintiff as
ttJAN E D O E''and her fam ily m em bers as tVJO HN D OE l7''EEJOHN D O E 11!$''and ECJO HN D OE
111,''respectively,exceptupon further orderofthe Court.
W H EREFORE, M ovant requests that the Court order the A ttorney-in-charge for
D efendant Texas A & M U niversity 12th M an Foundation to m aintain a list of a11 persons and
entities who are specifically and directly involved in the defense ofthis action, who have a need
Pursuant to Local nzle 7.1, Counsel for Plaintiff attem pted to confer with counsel for
D efendant as to whether Defendant opposed the relief soughtherein, butcounsel forD efendant
pprietortilpodhurst.com
igravante@ podhurst.com
TH E H AY ES LA W FIR M ,PC
700 Rockm ead,Suite 210
H ouston,Texas 77339-2111
Telephone:(281)-815-4963
Facsimile:(832)575-4759
DEBRA BR EW ER HAY ES
dhavesctzldhayeslaw.com
CHA RLES C LINTON H UN TER
chuntercc,dlzayeslaw.colAa
JIGN A V A CH H AN I
ivaclzlaalzi@dlAayeslaw.col4a
ATT O RN EY S FO R PLA IN TIFF
-2382
C ERTIFICA TE O F SER V IC E
1hereby certify thaton M arch 23, 20l5 lfiled the foregoing docum entw ith the Clerk of
the Court. lalso certify thatthe foregoing docum entisbeing served this day, via FedEx to Texas
A&M University 12thM an Foundation a/k/a The 12thM an Foundation, throug,
h registered agent
forservice ofprocess, RandelL.Howard,Joe RouttBlvd., C1
treet,
*M University
Cam pus,College Station,Texas77843.
/
PeterPrieto