1 Hon. Barbara J. Rothstein
2 3
4 5
6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON - AT SEATTLE
9 SHAZOR LOGISTICS, LLC, NO. 2:24-cv-00968 BJR
10 Plaintiff, STIPULATED MOTION TO SEAL 11 AND ORDER v.
12 AMAZON.COM, LLC and AMAZON 13 LOGISTICS, INC., Defendants. 14
15 STIPULATED MOTION TO SEAL 16 I. INTRODUCTION 17 By way of response to Plaintiff ShaZor Logistics, LLC’s Motion to Seal at Dkt. No. 5, and 18 pursuant to Local Civil Rule 5(g), Defendants Amazon.com, Inc. (identified as Amazon.com, LLC) 19 and Amazon Logistics, Inc. (together, “Amazon Logistics”) and Plaintiff ShaZor Logistics, LLC 20 (“ShaZor”) jointly move to seal and redact confidential exhibits filed provisionally under seal by 21 ShaZor with its Motion to Vacate. 22 23 24 25 26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 1 315 FIFTH AVENUE SOUTH, SUITE 1000 1 Specifically, the parties respectfully request that, with respect to the Declaration of Daimeon 2 Cotton filed at Dkt. Nos. 4 and 61, the Court maintain under seal Exhibits P, L, Y and BB and redact 3 confidential information from Exhibits C, H, I, J, and V (together, the “Confidential Exhibits”). 4 Amazon Logistics produced Exhibits H, I, J, L, P, Y and BB in discovery in the parties’ 5 underlying arbitration and these documents have been designated by Amazon Logistics as 6 “Confidential” under the protective order entered by the arbitration panel. Exhibit C comprises 7 excerpts of the transcript from the parties’ confidential final arbitration hearing on February 5 and 6, 8 2024, which is likewise designated as “Confidential” under the operative protective order, as is 9 Exhibit V, the final arbitration award. As set forth below, there are compelling reasons to maintain 10 information in these exhibits redacted and under seal. 11 II. BACKGROUND 12 In 2018, Amazon Logistics engaged ShaZor as a last-mile delivery provider to transport 13 packages from local delivery stations in Michigan to customers pursuant to the terms of the parties’ 14 contract, the Delivery Service Partner Agreement (“Agreement”). Dkt. No. 22, Ex. V at 1. The 15 Agreement provided for an initial one-year term and the possibility of renewal for successive terms, 16 although either party could avoid renewal via written notice within 30 days of the end of a term. Id. 17 at 1-2. The Agreement also included a confidentiality provision. Dkt. No. 22, Ex. CC § 7. Following 18 its fourth term, Amazon Logistics did not renew the contract at the end of its term, effective as of the 19 end of March 2022. Dkt. No. 22, Ex. N. 20 In June 2022, ShaZor sued Amazon Logistics in federal court. See generally Dkt. No. 4, Ex. 21 B. After Amazon Logistics successfully compelled arbitration, ShaZor brought the same claims in a 22 Demand for Arbitration dated October 2022. The parties selected an arbitration panel of three former 23 24
25 1 An amended version of Dkt. No. 6 was filed jointly by the parties at Dkt. No. 22. This Court struck Dkt. No. 6. as originally filed. Dkt. No. 23 (Order Granting Stipulated Motion to Strike and Replace Dkt. No. 6). 26 Accordingly, this motion is directed to the amended compilation of sealed exhibits, filed at Dkt. No. 22. STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 2 315 FIFTH AVENUE SOUTH, SUITE 1000 1 Washington State judges: the Honorable Laura Inveen (ret.), the Honorable Bruce Heller (ret.), and 2 the Honorable George Finkle (ret.). 3 On December 22, 2022, the panel entered a Stipulated Protective Order that had been jointly 4 proposed by the parties. The Protective Order designated as Confidential all matters relating to the 5 arbitration, including pleadings, discovery material, orders, and any interim or final award, barring 6 disclosure except in limited circumstances. 7 In February 2024, the parties participated in a two-day confidential arbitration on ShaZor’s 8 sole remaining claim of retaliation under 42 U.S.C. § 1981 (“Section 1981”).2 The full hearing 9 transcript was designated “Confidential,” as were the arbitration exhibits. Following the hearing, the 10 panel found in favor of Amazon Logistics, concluding ShaZor did not prove its claim. Dkt. No. 22, 11 Ex. V at 3-5. 12 On July 1, 2024, ShaZor petitioned this Court to vacate the arbitration award. Dkt. No. 1. It 13 also filed a memorandum supporting its petition (Dkt. No. 3), which this Court converted into a 14 motion to vacate by agreement of the parties, along with a declaration of counsel attaching publicly 15 filed exhibits (Dkt. No. 4), and a compilation of sealed exhibits (Dkt. No. 6). 16 The parties thereafter agreed to strike and replace the initially filed sealed exhibits (Dkt. No. 6) 17 with a narrowed compilation of sealed exhibits (Dkt. No. 22). The Court granted the parties’ stipulated 18 motion, replacing Dkt. No. 6 with the amended compilation of exhibits filed at Dkt. No. 22. See Dkt. 19 No. 23. As amended, Dkt. No. 6 comprises 24 hearing records (or excerpts thereof) from the parties’ 20 confidential arbitration. Of those exhibits, the parties ask the Court to maintain under seal four exhibits: Exhibit P (a PowerPoint presentation), Exhibit L (terms of an offer to ShaZor), and 21 Exhibits Y and BB (instant message conversations). The parties also ask the Court to redact 22 confidential and proprietary portions of five other exhibits: Exhibit C (hearing testimony of an 23 Amazon Logistics witness), Exhibits H, I, and J (legal notices issued to ShaZor), and Exhibit V (the 24 arbitration award). 25
26 2 The panel dismissed ShaZor’s other claims at summary judgment. Dkt. No. 4, Ex. S. STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 3 315 FIFTH AVENUE SOUTH, SUITE 1000 III. CERTIFICATION OF LCR 5 CONFERENCE 1 In compliance with Local Civil Rule 5(g)(3)(A), counsel for Amazon Logistics, Diana Breaux 2 and Eva Oliver, conferred with counsel for ShaZor, Nathan Nanfelt and Daimeon Cotton, via Zoom 3 videoconferences on August 22, 2024, and August 29, 2024. The parties agreed to strike and replace 4 the compilation of exhibits originally filed by ShaZor with an amended version containing excerpts, 5 where appropriate, to narrow the scope of sealed documents at issue in this motion. Accordingly, the 6 parties filed a stipulated motion strike and replace Dkt. No. 6 with an amended version on August 29, 7 2024, and contemporaneously filed the amended exhibits under seal.3 See Dkt. Nos. 21-22. The Court 8 granted the parties’ stipulated motion. Dkt. No. 23. This motion is therefore directed to the amended 9 exhibits. ShaZor joins Amazon Logistics’ requests to seal and redact. 10 IV. ARGUMENT 11 Through this stipulated motion to seal, the parties ask this Court to maintain under seal only 12 a fraction of the record of the confidential arbitration submitted with ShaZor’s Motion to Vacate (four 13 exhibits and portions of five others) based on the confidential and commercially sensitive information 14 about Amazon’s Delivery Service Partner (“DSP”) program contained therein. 15 A. Legal Standard 16 Although there exists a “strong presumption in favor of access [to court records],” Kamakana 17 v. City & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006), this presumption “is not absolute 18 and can be overridden given sufficiently compelling reasons for doing so,” Foltz v. State Farm Mut. 19 Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003). Courts must “conscientiously balance” the 20 interest of the public’s access with the reasons a party seeks to keep a document or information 21 private. See Kamakana, 447 F.3d at 1179. 22 A court may seal records when there is a “compelling reason” to do so. Ctr. for Auto Safety v.
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1 Hon. Barbara J. Rothstein
2 3
4 5
6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON - AT SEATTLE
9 SHAZOR LOGISTICS, LLC, NO. 2:24-cv-00968 BJR
10 Plaintiff, STIPULATED MOTION TO SEAL 11 AND ORDER v.
12 AMAZON.COM, LLC and AMAZON 13 LOGISTICS, INC., Defendants. 14
15 STIPULATED MOTION TO SEAL 16 I. INTRODUCTION 17 By way of response to Plaintiff ShaZor Logistics, LLC’s Motion to Seal at Dkt. No. 5, and 18 pursuant to Local Civil Rule 5(g), Defendants Amazon.com, Inc. (identified as Amazon.com, LLC) 19 and Amazon Logistics, Inc. (together, “Amazon Logistics”) and Plaintiff ShaZor Logistics, LLC 20 (“ShaZor”) jointly move to seal and redact confidential exhibits filed provisionally under seal by 21 ShaZor with its Motion to Vacate. 22 23 24 25 26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 1 315 FIFTH AVENUE SOUTH, SUITE 1000 1 Specifically, the parties respectfully request that, with respect to the Declaration of Daimeon 2 Cotton filed at Dkt. Nos. 4 and 61, the Court maintain under seal Exhibits P, L, Y and BB and redact 3 confidential information from Exhibits C, H, I, J, and V (together, the “Confidential Exhibits”). 4 Amazon Logistics produced Exhibits H, I, J, L, P, Y and BB in discovery in the parties’ 5 underlying arbitration and these documents have been designated by Amazon Logistics as 6 “Confidential” under the protective order entered by the arbitration panel. Exhibit C comprises 7 excerpts of the transcript from the parties’ confidential final arbitration hearing on February 5 and 6, 8 2024, which is likewise designated as “Confidential” under the operative protective order, as is 9 Exhibit V, the final arbitration award. As set forth below, there are compelling reasons to maintain 10 information in these exhibits redacted and under seal. 11 II. BACKGROUND 12 In 2018, Amazon Logistics engaged ShaZor as a last-mile delivery provider to transport 13 packages from local delivery stations in Michigan to customers pursuant to the terms of the parties’ 14 contract, the Delivery Service Partner Agreement (“Agreement”). Dkt. No. 22, Ex. V at 1. The 15 Agreement provided for an initial one-year term and the possibility of renewal for successive terms, 16 although either party could avoid renewal via written notice within 30 days of the end of a term. Id. 17 at 1-2. The Agreement also included a confidentiality provision. Dkt. No. 22, Ex. CC § 7. Following 18 its fourth term, Amazon Logistics did not renew the contract at the end of its term, effective as of the 19 end of March 2022. Dkt. No. 22, Ex. N. 20 In June 2022, ShaZor sued Amazon Logistics in federal court. See generally Dkt. No. 4, Ex. 21 B. After Amazon Logistics successfully compelled arbitration, ShaZor brought the same claims in a 22 Demand for Arbitration dated October 2022. The parties selected an arbitration panel of three former 23 24
25 1 An amended version of Dkt. No. 6 was filed jointly by the parties at Dkt. No. 22. This Court struck Dkt. No. 6. as originally filed. Dkt. No. 23 (Order Granting Stipulated Motion to Strike and Replace Dkt. No. 6). 26 Accordingly, this motion is directed to the amended compilation of sealed exhibits, filed at Dkt. No. 22. STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 2 315 FIFTH AVENUE SOUTH, SUITE 1000 1 Washington State judges: the Honorable Laura Inveen (ret.), the Honorable Bruce Heller (ret.), and 2 the Honorable George Finkle (ret.). 3 On December 22, 2022, the panel entered a Stipulated Protective Order that had been jointly 4 proposed by the parties. The Protective Order designated as Confidential all matters relating to the 5 arbitration, including pleadings, discovery material, orders, and any interim or final award, barring 6 disclosure except in limited circumstances. 7 In February 2024, the parties participated in a two-day confidential arbitration on ShaZor’s 8 sole remaining claim of retaliation under 42 U.S.C. § 1981 (“Section 1981”).2 The full hearing 9 transcript was designated “Confidential,” as were the arbitration exhibits. Following the hearing, the 10 panel found in favor of Amazon Logistics, concluding ShaZor did not prove its claim. Dkt. No. 22, 11 Ex. V at 3-5. 12 On July 1, 2024, ShaZor petitioned this Court to vacate the arbitration award. Dkt. No. 1. It 13 also filed a memorandum supporting its petition (Dkt. No. 3), which this Court converted into a 14 motion to vacate by agreement of the parties, along with a declaration of counsel attaching publicly 15 filed exhibits (Dkt. No. 4), and a compilation of sealed exhibits (Dkt. No. 6). 16 The parties thereafter agreed to strike and replace the initially filed sealed exhibits (Dkt. No. 6) 17 with a narrowed compilation of sealed exhibits (Dkt. No. 22). The Court granted the parties’ stipulated 18 motion, replacing Dkt. No. 6 with the amended compilation of exhibits filed at Dkt. No. 22. See Dkt. 19 No. 23. As amended, Dkt. No. 6 comprises 24 hearing records (or excerpts thereof) from the parties’ 20 confidential arbitration. Of those exhibits, the parties ask the Court to maintain under seal four exhibits: Exhibit P (a PowerPoint presentation), Exhibit L (terms of an offer to ShaZor), and 21 Exhibits Y and BB (instant message conversations). The parties also ask the Court to redact 22 confidential and proprietary portions of five other exhibits: Exhibit C (hearing testimony of an 23 Amazon Logistics witness), Exhibits H, I, and J (legal notices issued to ShaZor), and Exhibit V (the 24 arbitration award). 25
26 2 The panel dismissed ShaZor’s other claims at summary judgment. Dkt. No. 4, Ex. S. STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 3 315 FIFTH AVENUE SOUTH, SUITE 1000 III. CERTIFICATION OF LCR 5 CONFERENCE 1 In compliance with Local Civil Rule 5(g)(3)(A), counsel for Amazon Logistics, Diana Breaux 2 and Eva Oliver, conferred with counsel for ShaZor, Nathan Nanfelt and Daimeon Cotton, via Zoom 3 videoconferences on August 22, 2024, and August 29, 2024. The parties agreed to strike and replace 4 the compilation of exhibits originally filed by ShaZor with an amended version containing excerpts, 5 where appropriate, to narrow the scope of sealed documents at issue in this motion. Accordingly, the 6 parties filed a stipulated motion strike and replace Dkt. No. 6 with an amended version on August 29, 7 2024, and contemporaneously filed the amended exhibits under seal.3 See Dkt. Nos. 21-22. The Court 8 granted the parties’ stipulated motion. Dkt. No. 23. This motion is therefore directed to the amended 9 exhibits. ShaZor joins Amazon Logistics’ requests to seal and redact. 10 IV. ARGUMENT 11 Through this stipulated motion to seal, the parties ask this Court to maintain under seal only 12 a fraction of the record of the confidential arbitration submitted with ShaZor’s Motion to Vacate (four 13 exhibits and portions of five others) based on the confidential and commercially sensitive information 14 about Amazon’s Delivery Service Partner (“DSP”) program contained therein. 15 A. Legal Standard 16 Although there exists a “strong presumption in favor of access [to court records],” Kamakana 17 v. City & Cnty. of Honolulu, 447 F.3d 1172, 1178 (9th Cir. 2006), this presumption “is not absolute 18 and can be overridden given sufficiently compelling reasons for doing so,” Foltz v. State Farm Mut. 19 Auto. Ins. Co., 331 F.3d 1122, 1135 (9th Cir. 2003). Courts must “conscientiously balance” the 20 interest of the public’s access with the reasons a party seeks to keep a document or information 21 private. See Kamakana, 447 F.3d at 1179. 22 A court may seal records when there is a “compelling reason” to do so. Ctr. for Auto Safety v. 23 Chrysler Grp., LLC, 809 F.3d 1092, 1096–97 (9th Cir. 2016). “What constitutes a ‘compelling reason’ 24 25 3 The parties also moved to strike and remove from the docket Exhibit V, which was originally filed publicly 26 and is now in the record under seal as contemplated by the parties’ Stipulated Protective Order. STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 4 315 FIFTH AVENUE SOUTH, SUITE 1000 1 is ‘best left to the sound discretion of the trial court.’ Examples include when a court record might be 2 used to ‘gratify private spite or promote public scandal,’ to circulate ‘libelous’ statements, or ‘as 3 sources of business information that might harm a litigant’s competitive standing.’” Id. (quoting 4 Nixon v. Warner Commc’ns, Inc., 435 U.S. 589, 598–99 (1978)). 5 Courts routinely seal “business information that might harm a litigant’s competitive standing.” 6 In re Elec. Arts, Inc., 298 F. App’x 568, 569 (9th Cir. 2008) (quoting Nixon v. Warner Commc’ns, 7 Inc., 435 U.S. 589, 598 (1978)). For example, proprietary business methods and practices, business 8 policies and procedures related to operations, and business analytics. Id. (sealing licensing agreement 9 containing pricing terms, royalty rates, and guaranteed minimum payment terms); Hill v. Xerox Corp., 10 No. C12-0717-JCC, 2014 WL 1356212, at *2 (W.D. Wash. Apr. 7, 2014) (sealing employee 11 compensation plans); Fed. Trade Comm’n v. Kroger Co., No. 3:24-CV-00347-AN, 2024 WL 12 1526504, at *1 (D. Or. Apr. 8, 2024) (finding compelling reasons warranted sealing “confidential 13 business and operations strategies” and “analytical methods”). 14 Additionally, under Local Civil Rule 5(g), the party who designates a document confidential 15 must provide a “specific statement of the applicable legal standard and the reasons for keeping a 16 document under seal, including an explanation of: (i) the legitimate private or public interests that 17 warrant the relief sought; (ii) the injury that will result if the relief sought is not granted; and (iii) why 18 a less restrictive alternative to the relief sought is not sufficient.” See LCR 5(g)(3)(B). 19 B. Compelling Reasons Warrant the Requested Confidential Treatment. 20 Each of the Confidential Exhibits contains highly confidential and commercially sensitive 21 information about Amazon Logistics’ administration and operation of its DSP program. 22 • Exhibit C comprises excerpts from the multi-day arbitration hearing transcript. The 23 parties seek to redact portions of testimony of Amazon Logistics witnesses as to the 24 confidential methods and practices Amazon Logistics’ Network Health team uses in 25 deciding whether to renew business contracts with delivery service partners, as well 26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 5 315 FIFTH AVENUE SOUTH, SUITE 1000 1 as the process by which Amazon Logistics issues breach of contract notices and 2 analytics reflecting the same. 3 • Exhibits H, I, and J are legal notices Amazon Logistics issued to ShaZor. The parties 4 ask to redact references to terms of the Program Policies, a non-public document 5 containing confidential, commercially sensitive terms of the DSP Program. 6 • Exhibit L is an email to ShaZor which, in its entirety, reflects confidential terms of an 7 offer to end the parties’ business contract. 8 • Exhibits Y and BB are instant message conversations. With the exception of a small 9 portion of page two that ShaZor cites in its motion, Exhibit Y includes extraneous 10 information relating to third party businesses and Amazon Logistics’ operations 11 unrelated to this matter and yet reveal proprietary information about Amazon 12 Logistics’ internal processes regarding routing, fleet management, enforcement of 13 program requirements, and station management. The portion of the exhibit cited in 14 ShaZor’s motion reflects confidential information revealing Amazon Logistics’ 15 business processes and strategy. The parties accordingly seek to keep the exhibit in its 16 entirety under seal. Exhibit BB likewise comprises confidential information about 17 Amazon Logistics’ internal processes regarding routing, fleet management, and 18 enforcement of program requirements, such that redactions would be impractical. 19 • Exhibit P is a PowerPoint presentation that includes aggregate data on the 20 performance of hundreds of non-party businesses that partner with Amazon Logistics 21 through the DSP program. Each substantive slide of the PowerPoint reflects such 22 confidential material and, therefore, redactions are infeasible. 23 • Exhibit V is the arbitration award, deemed confidential under the parties’ agreed 24 protective order, as to which the parties seek leave to redact confidential portions 25 consistent with the proposed redactions to the hearing transcript (Exhibit C) and legal 26 notices (Exhibits H, I, and J). STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 6 315 FIFTH AVENUE SOUTH, SUITE 1000 1 In short, each of these documents contains highly confidential and commercially sensitive 2 information about Amazon Logistics’ operation of its DSP program. Public disclosure of this 3 information could cause Amazon Logistics competitive harm. By proposing redactions wherever 4 possible, the parties have proposed the least restrictive means sufficient to protect Amazon Logistics’ 5 interests. 6 At the same time, the public’s interest in access to this information is minimal as the redacted 7 information has only a tenuous connection to the issues before this Court. Mobiloc, LLC v. Neutron 8 Holdings, Inc., 555 F. Supp. 3d 1040, 1047 (W.D. Wash. 2021) (granting motion to seal where 9 materials “contain[ed] confidential and sensitive business information in which the public has a 10 minimal interest”). ShaZor cites the subject exhibits only for background. Dkt. No. 3. Amazon 11 Logistics, for its part, cites portions of testimony in Exhibit C only to refute ShaZor’s claim that the 12 tribunal relied on evidence not in the record. Further, the FAA specifically precludes this Court from 13 re-weighing the evidence or revisiting disputed issues of fact resolved by the tribunal. Put simply, 14 this Court cannot engage in fact finding in resolving ShaZor’s Motion to Vacate; rather, the Court’s 15 review is limited to whether the award reflects manifest disregard of applicable law or evident 16 partiality on the part of the tribunal. Given the narrow scope of this proceeding, the public cannot be 17 said to have an interest in immaterial confidential information admitted as evidence in the underlying 18 arbitration. On balance, compelling reasons to seal far outweigh the public’s interest in portions of 19 the arbitration hearing record filed to provide background context. 20 V. CONCLUSION 21 For the foregoing reasons, the parties respectfully ask the Court to maintain Exhibits L, P, Y 22 and BB under seal and to permit the redaction of confidential portions of Exhibits C, H, I, J, and V, 23 as filed herewith. 24 25 26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 7 315 FIFTH AVENUE SOUTH, SUITE 1000 1 STIPULATED this 3rd day of September, 2024. 2 I certify that this memorandum contains 2,068 words, in compliance with the Local Civil 3 Rules. 4 5 KELLER ROHRBACK L.L.P.
6 s/Nathan L. Nanfelt (with authorization given) Juli E. Farris, WSBA #17593 7 jfarris@kellerrohrback.com Nathan L. Nanfelt, WSBA #45273 8 nnanfelt@kellerrohrback.com 9 1201 Third Avenue, Suite 3200 Seattle, WA 98101 10 Tel: (206) 623-1900
11 Daimeon Montrez Cotton, MI License #P75563 Admitted Pro Hac Vice 12 dcotton@cottonlawcenter.com 13 COTTON LAW CENTER, PLLC 13900 Woodward Avenue 14 Highland Park, MI 48203 Tel: (313) 998-2017 15 Counsel for Plaintiff 16
17 SUMMIT LAW GROUP, PLLC 18
19 s/Diana Siri Breaux Diana Siri Breaux, WSBA #46112 20 dianab@summitlaw.com Selby P. Brown, WSBA #59303 21 selbyb@summitlaw.com Hathaway Burden, WSBA #52970 22 hathawayb@summitlaw.com 23 Eva Sharf Oliver, WSBA #57019 evao@summitlaw.com 24 315 Fifth Avenue S., Suite 1000 Seattle, WA 98104-2682 25 (206) 676-7000 26 Counsel for Defendants STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 8 315 FIFTH AVENUE SOUTH, SUITE 1000 1 ORDER
2 Upon consideration of the parties’ jointly filed Stipulated Motion to Seal, filed on 3 September 3, 2024, the Court finds as follows: 4 1. There are compelling reasons to seal Exhibits L, P, Y and BB in full and to seal the 5 redacted portions of Exhibits C, H, I, J, and V. Each of these exhibits contains highly 6 confidential and commercially sensitive information about Amazon Logistics’ 7 administration and operation of its Delivery Service Partner program, public disclosure 8 of which could cause Amazon Logistics competitive harm. 9 2. The public’s interest in access to this information is minimal. The sealed information 10 was included with Plaintiff’s motion to vacate for the purpose of providing background 11 context and has only a tenuous connection to the issues before this Court. Public access 12 to these records will not meaningfully further the public’s understanding of this judicial 13 proceeding. 14 Accordingly, the Court GRANTS the parties’ Stipulated Motion to Seal and ORDERS the Clerk to 15 maintain Exhibits L, P, Y, and BB under seal and to maintain the unredacted versions of Exhibits 16 C, H, I, J, and V under seal. 17 IT IS SO ORDERED. 18 Dated this 1st day of October 2024. 19
21 A
22 Honorable Barbara J. Rothstein 23 UNITED STATES DISTRICT COURT JUDGE
26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 9 315 FIFTH AVENUE SOUTH, SUITE 1000 1 CERTIFICATE OF SERVICE 2 I, Kathi Milner, hereby certify under penalty of perjury of the laws of the State of Washington 3 that on September 3, 2024, I caused a true and correct electronic copy of the foregoing document to 4 be served on the following and in the manner indicated: 5 Counsel for Plaintiff:
Juli E. Farris, WSBA #17593 7 jfarris@kellerrohrback.com CM/ECF System Email Nathan L. Nanfelt, WSBA #45273 8 nnanfelt@kellerrohrback.com
9 KELLER ROHRBACK L.L.P.
1201 Third Avenue, Suite 3200
10 Seattle, WA 98101
Tel: (206) 623-1900 11 Ju 12 Daimeon Montrez Cotton, MI License #P75563 CM/ECF System 13 Admitted Pro Hac Vice Email dcotton@cottonlawcenter.com 14 COTTON LAW CENTER, PLLC 13900 Woodward Avenue 15 Highland Park, MI 48203 Tel: (313) 998-2017 16 17 18 DATED this 3rd day of October, 2024, at Seattle, King County, Washington. 19 SUMMIT LAW GROUP, PLLC
20 s/Kathi Milner Kathi Milner, Legal Assistant 21 kathim@summitlaw.com 22 23 24 25 26 STIPULATED MOTION TO SEAL AND SUMMIT LAW GROUP, PLLC ORDER - 10 315 FIFTH AVENUE SOUTH, SUITE 1000