1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NOTICE OF ERRATA REGARDING JOINT STIPULATION ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS, 10-09198 JVS(RNBx) JONATHAN A. SHAPIRO (257199) JOEL FLEMING (281264) WILMER CUTLER PICKERING HALE AND DORR LLP 950 Page Mill Road Palo Alto, CA 94304 Tel: (650) 858-6101 Fax: (650) 858-6100 jonathan.shapiro@wilmerhale.com ANDREA J. ROBINSON (PRO HAC VICE) TIMOTHY J. PERLA (PRO HAC VICE) WILMER CUTLER PICKERING HALE AND DORR LLP 60 State Street Boston, MA 02109 Tel: (617) 526-6000 Fax: (617) 526-5000 andrea.robinson@wilmerhale.com timothy.perla@wilmerhale.com Attorneys for Defendant Life Insurance Company of the Southwest UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA SOUTHERN DIVISION JOYCE WALKER, KIM BRUCE HOWLETT, and MURIEL SPOONER on behalf of themselves and all others similarly situated, Plaintiffs, vs. LIFE INSURANCE COMPANY OF THE SOUTHWEST, a Texas corporation, and DOES 1-50, Defendant. Case No.: 10-09198 JVS(RNBx) LIFE INSURANCE COMPANY OF THE SOUTHWEST’S NOTICE OF ERRATA REGARDING PUBLIC, REDACTED VERSION OF JOINT STIPULATION OF POINTS AND AUTHORITY ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS Magistrate Judge Robert N. Block Courtroom: 6D Case 2:10-cv-09198-JVS -RNB Document 188 Filed 04/03/12 Page 1 of 4 Page ID #:7859 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 2 - NOTICE OF ERRATA REGARDING JOINT STIPULATION ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS, 10-09198 JVS(RNBx) NOTICE OF ERRATA Docket entries 131 through 131-6 (collectively, the parties’ Joint Stipulation of Points and Authority on LSW’s Motion for Protective Order and to Compel Responses to Deposition Questions) were inadvertently and incorrectly filed electronically in their unredacted form. That document should have been filed electronically in a redacted form. Believing, in error, that a redacted version of the joint stipulation had been filed electronically, LSW also manually filed, under seal, another unredacted version of the joint stipulation. See Dkt. 142. The Court granted the parties’ joint application to seal the manually filed unredacted version of the joint stipulation. See Dkt. 143. The underlying motion has already been decided by the Court. See Dkt. 159; Dkt. 169. Concurrently with this Notice of Errata, LSW is filing manually an application to Seal docket entries 131 through 131-6 (the unredacted Joint Stipulation of Points and Authority on LSW’s Motion for Protective Order and To Compel Responses to Deposition Questions that was erroneously filed electronically). Pursuant to the Court’s Second Amended Protective Order in this action, Dkt. 102 at 10 (Sept. 26, 2011), the parties are required to file a redacted version of any sealed document. Therefore, attached to this Notice of Errata is an amended Joint Stipulation that is identical to the version that was previously filed electronically, except that it redacts certain confidential information that appears in the unredacted version. Case 2:10-cv-09198-JVS -RNB Document 188 Filed 04/03/12 Page 2 of 4 Page ID #:7860 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 3 - NOTICE OF ERRATA REGARDING JOINT STIPULATION ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS, 10-09198 JVS(RNBx) Dated: April 3, 2012 Respectfully submitted, WILMER CUTLER PICKERING HALE AND DORR LLP By: /s/ Joel Fleming Jonathan A. Shapiro (257199) Andrea J. Robinson (pro hac vice) Timothy J. Perla (pro hac vice) Joel Fleming (281264) Attorneys for Defendant Life Insurance Company of the Southwest Case 2:10-cv-09198-JVS -RNB Document 188 Filed 04/03/12 Page 3 of 4 Page ID #:7861 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 - 4 - NOTICE OF ERRATA REGARDING JOINT STIPULATION ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS, 10-09198 JVS(RNBx) PROOF OF SERVICE I am a resident of the State of California, over the age of eighteen years, and not a party to the within action. My business address is Wilmer Cutler Pickering Hale and Dorr LLP, 950 Page Mill Road, Palo Alto, CA 94304. On April 3, 2012 I served the within document(s): LIFE INSURANCE COMPANY OF THE SOUTHWEST’S NOTICE OF ERRATA REGARDING PUBLIC, REDACTED VERSION OF JOINT STIPULATION OF POINTS AND AUTHORITY ON LSW’S MOTION FOR PROTECTIVE ORDER AND TO COMPEL RESPONSES TO DEPOSITION QUESTIONS I placed the document(s) listed above in a sealed envelope with postage thereon fully prepaid, in the United States mail at Palo Alto, CA addressed as set forth below. I personally caused to be emailed the document(s) listed above to the person(s) at the address(es) set forth below.  I electronically filed the document(s) listed above via the CM/ECF system. Brian Brosnahan Charles N. Freiberg Jacob Foster Jeanette Barzelay KASOWITZ, BENSON, TORRES & FRIEDMAN LLP 101 California Street, Suite 2300 San Francisco, CA 94111 cfreiberg@kasowitz.com Harvey R. Levine LEVINE & MILLER 550 West C. Street, Suite 1810 San Diego, CA 92101-8596 lsmh@levinelaw.com /s/ Joel Fleming Joel Fleming Case 2:10-cv-09198-JVS -RNB Document 188 Filed 04/03/12 Page 4 of 4 Page ID #:7862