Professional Documents
Culture Documents
COMES NOW, Plaintiff JANE DOE, by and through her attorneys, Clark Law Firm,
1. Jane Doe has lodged her Complaint in this Circuit Court, praying for Declaratory
2. In order for the Court to make a determination in this matter, the records at issue
must be provided, and the parties counsel must be permitted to discuss them openly with the Court.
3. Absent an order sealing the record, any records provided or arguments made to the
Court would be a matter of public record, which would effectively nullify any opportunity to
protect the privacy of Jane Doe and for the Court to provide the requested relief.
4. Plaintiff therefore respectfully requests that the Court permit her to provide the
records at issue in this cause to the Court under seal, and further to close any hearing on the matter,
4817-2029-3229, v. 1 1
WHEREFORE, Plaintiff, Jane Doe, prays this Court Grant her Motion to Seal Record, for
her costs and attorney’s fees, and for all other relief to which she may be entitled.
CERTIFICATE OF SERVICE
I, Suzanne G. Clark, certify that on this 24th day of July, 2018, that I electronically filed
the foregoing pleading with the Clerk of the Court using the Court’s eFlex system, which shall
provide notification of the filing to counsel of record below:
4817-2029-3229, v. 1 2