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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Plaintiff,
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`v.
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`Case No.: 2:22-CV-00486-JRG
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`JURY TRIAL DEMANDED
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`NORTHSTAR SYSTEMS LLC,
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`VOLKSWAGEN AG,
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`Defendant.
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`UNOPPOSED MOTION FOR LEAVE TO FILE UNDER SEAL
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`Pursuant to Eastern District of Texas Local Rule 5(a)(7)(C), Defendant Volkswagen AG
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`(“VWAG”) moves to file under seal its Motion to Dismiss or Alternatively to Transfer
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`(“Motion”) and Exhibit 3 to said Motion.
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`VWAG’s Exhibit 3 discusses highly confidential business information related to the
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`operation of a third-party to this litigation. VWAG’s Motion cites to the confidential information
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`contained in Exhibit 3. There is currently no Protective Order entered in this matter.
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`Accordingly, to preserve the confidentiality of that information, VWAG respectfully requests
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`that the Motion and Exhibit 3 be filed under seal.
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`VWAG has conferred with Plaintiff NorthStar in advance of the filing of this motion, and
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`NorthStar has stated that it does not oppose VWAG’s request to seal the information contained
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`in Exhibit 3. Pursuant to Local Rule CV-5(a)(7)(E), a redacted version of Exhibit 3 and the
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`Motion will be filed within seven days.
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`Case 2:22-cv-00486-JRG Document 9 Filed 05/30/23 Page 2 of 3 PageID #: 39
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`Dated: May 30, 2023
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`Of Counsel:
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`Daniel E. Yonan (pro hac pending)
`Michael D. Specht (pro hac pending)
`Daniel Block (pro hac pending)
`William H. Milliken (pro hac pending)
`Lauren A. Watt (pro hac pending)
`STERNE, KESSLER, GOLDSTEIN & FOX
`P.L.L.C
`1100 New York Avenue NW, Suite 600
`Washington, DC 20005
`(202) 371-2600
`dyonan@sternekessler.com
`mspecht@sternekessler.com
`dblock@sternekessler.com
`wmilliken@sternekessler.com
`lwatt@sternekessler.com
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`/s/ Michael C. Smith
`Michael Smith (No. 18650410)
`SCHEEF & STONE, LLP
`113 East Austin Street
`Marshall, Texas 75670
`(903) 938-8900
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`Attorneys for Defendant
`Volkswagen AG
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`Case 2:22-cv-00486-JRG Document 9 Filed 05/30/23 Page 3 of 3 PageID #: 40
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`CERTIFICATE OF CONFERENCE
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`Pursuant to Local Rule CV-7(h), the parties met and conferred regarding the foregoing
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`motion on May 30, 2023, and this motion is being filed as unopposed.
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`/s/ Michael C. Smith
` Michael C. Smith
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that all counsel of record who have consented to electronic
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`service are being served with a copy of this document via the Court’s CM/ECF system on this
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`the 30th day of May, 2023.
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`/s/Michael C. Smith
` Michael C. Smith
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