Case 3:18-cv-00050-JD Document 30 Filed 02/17/18 Page 1 of 3

LAW OFFICES OF YOLANDA HUANG

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YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
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5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
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Attorneys for Plaintiffs
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10 UNITED STATES DISTRICT COURT
11 FOR THE NORTHERN DISTRICT OF CALIFORNIA
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13 JACLYN MOHRBACHER, ERIN ELLIS,
DOMINIQUE JACKSON, CHRISTINA
14 No. 3:18-cv-00050-JD
ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others
15 PLAINTIFFS’ ADMINISTRATIVE MOTION
similarly situated,
TO FILE UNDER SEAL ¶¶9-12 AND
16 Plaintiffs, EXHIBIT A OF THE DECLARATION OF
17 YOLANDA HUANG IN SUPPORT OF P
vs. PLAINTIFFS’ REPLY TO COUNTY
18 DEFENDANTS’ LETTER OF 2/13/18, and
ALAMEDA COUNTY SHERIFF’S OFFICE, et OPPOSITION TO CFMG DEFENDANTS’
19 REQUEST FOR EXTENSION OF TIME
al.,
20 Defendants.
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Pursuant to N.D. Cal. Civil Local Rule 79-5(d), Plaintiffs hereby moves the Court to issue an
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administrative order that authorizes the sealing of Paragraphs 9 through 12 of the Declaration of
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Yolanda Huang and Exhibit A to the Declaration in Support of Plaintiffs’ Opposition to Defendant
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California Forensic Medical Group, Inc.’s Request For An Extension Of Time And Response To
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Defendants Alameda County Sheriffs’ Office Letter To The Court. The Declaration of Yolanda
26 Huang and Exhibit A contain materials privileged under the attorney client privilege and is subject to
27 safeguard under Federal Rule of Evidence 501. The basis for plaintiff’s administrative motion is set
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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Administrative Motion to File Under Seal
 Case 3:18-cv-00050-JD Document 30 Filed 02/17/18 Page 2 of 3

forth in the Declaration of Yolanda Huang submitted herewith. A proposed order granting Plaintiffs’
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administrative motion and authorizing the sealing of the document is also submitted herewith.
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Dated: February 16, 2018 Respectfully submitted,
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LAW OFFICE OF YOLANDA HUANG
5 /s/ Yolanda Huang______
6 YOLANDA HUANG

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DENNIS CUNNINGHAM
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/s/ Dennis Cunningham___
9 DENNIS CUNNINGHAM

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ATTORNEYS FOR PLAINTIFFS
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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Administrative Motion to File Under Seal
 Case 3:18-cv-00050-JD Document 30 Filed 02/17/18 Page 3 of 3

DECLARATION OF YOLANDA HUANG IN SUPPORT OF

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PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE UNDER SEAL
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1. I am an attorney licensed to practice law in the State of California and am counsel of record
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for Plaintiffs in this action. I submit this Declaration in support of Plaintiffs’ Administrative Motion
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to File Under Seal paragraphs 9 thru 12 and Exhibit A of the Declaration of Yolanda Huang in
5 Support of Plaintiffs’ Opposition to Defendant California Forensic Medical Group, Inc.’s Request
6 For An Extension Of Time And Response To Defendants Alameda County Sheriffs’ Office Letter To
7 The Court. I have personal knowledge of the facts stated herein and if called to testify could and
8 would competently testify thereto.
9 2. Exhibit A and ¶¶9-12 of Declaration of Yolanda Huang In Support of Plaintiffs’ Opposition

10 to Defendant California Forensic Medical Group, Inc.’s Request For An Extension Of Time And
Response To Defendants Alameda County Sheriffs’ Office Letter To The Court is sealable as it
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contains and refers to communications between myself and plaintiffs and members of the plaintiff
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class, said communications was in the course of this litigation, and is therefore, subject to protection
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as attorney client information.
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I declare under penalty of perjury that the foregoing is true and correct to the best of my
15 knowledge and understanding. Executed this 14th day of February in Berkeley, California.
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17 /s/ Yolanda Huang______
YOLANDA HUANG
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Mohrbacher v. Alameda County Sheriff’s Office 3:18-cv-00050, Administrative Motion to File Under Seal
 Case 3:18-cv-00050-JD Document 30-1 Filed 02/17/18 Page 1 of 2

LAW OFFICES OF YOLANDA HUANG

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YOLANDA HUANG, SBN 104543
2 475 14th Street, Suite 500
Oakland, CA 94612
3 Telephone: (510) 329-2140
Facsimile: (510) 580-9410
4
5 DENNIS CUNNINGHAM, SBN 112910
115A Bartlett St.
6 San Francisco, CA 94110
7 Telephone: 415-285-8091
Facsimile: 415-285-8092
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Attorneys for Plaintiffs
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11 UNITED STATES DISTRICT COURT
12 FOR THE NORTHERN DISTRICT OF CALIFORNIA

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JACLYN MOHRBACHER, ERIN ELLIS,
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DOMINIQUE JACKSON, CHRISTINA
No. 3:18-cv-00050-JD
16 ZEPEDA, ALEXIS WAH, AND KELSEY
ERWIN, on behalf of themselves and others
17 similarly situated,
[PROPOSED] ORDER GRANTING
18 Plaintiffs, PLAINTIFFS’ADMINISTRATIVE MOTION
TO FILE UNDER SEAL
19 vs.
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ALAMEDA COUNTY SHERIFF’S OFFICE, et
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al.,
22 Defendants.

23 As set forth in Plaintiffs’ Administrative Motion to File Under Seal, Plaintiffs lodged with
24 the Court the following document containing information designated by Plaintiffs
25 1. ¶¶ 9-12 of the Declaration of Yolanda Huang;
26 2. Declaration A attached to the Declaration of Yolanda Huang.

27 Having considered plaintiffs’ Administrative Motion Application made pursuant to Civil Local
Rule 79-5(d) in support of sealing, and good cause appearing therefore;
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[PROPOSED] ORDER GRANTING PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE: 3:18-cv-00050,
 Case 3:18-cv-00050-JD Document 30-1 Filed 02/17/18 Page 2 of 2

IT IS HEREBY ORDERED that the above referenced document is to be filed under seal.
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Dated: _____________________, 2018 _______________________________
5 Hon. James Donato
United States District Judge
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[PROPOSED] ORDER GRANTING PLAINTIFFS’ ADMINISTRATIVE MOTION TO FILE UNDER SEAL
CASE: 3:18-cv-00050,