Case Doc 4015 Filed 09/04/14 Entered 09/04/14 15:16:53 Desc Main Document Page 1 of 13

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1 Document Page 1 of 13 UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION IN RE: * CASE NO. 10-BK GARLOCK SEALING * CHAPTER 11 TECHNOLOGIES, LLC, ET AL., DEBTORS * JOINTLY ADMINISTERED ROUSSEL & CLEMENT CLAIMANTS MOTION TO SEAL Claimants, Bonnie A. Marchand, Patricia Marchand Picou, Dudley L. Marchand, III, Wayne M. Marchand, Rebecca Marchand Kennedy, Charmaine Marchand Bizette, and Brett L. 1 Marchand, Jeanette Garnett Pichon, Roland L. Pichon, Mark P. Pichon, Patrice Pichon 2 Robinson, Tracy Pichon Baham, Veronica Pichon Joseph, and Cade Pichon Hagger, Donald Francis Rome, individually and as curator on behalf of, Inez Rome, and Nathan Rome, Marcella 3 4 Rome Kliebert, Sally Becnel Tregre, and Margaret Cortez Rome, Fay Thibodeaux Danos, Julie 5 Danos Landry, Jill Danos Trosclair, and Jana Danos Anzelmo, Audie Dufrene, Leonelle Dufrene 1 Bonnie A. Marchand, Patricia Marchand Picou, Dudley L. Marchand, III, Wayne M. Marchand, Rebecca Marchand Kennedy, Charmaine Marchand Bizette, and Brett L. Marchand are the children of Dudley Marchand, Jr. 2 Jeanette Garnett Pichon is the widow of Leon R. Pichon. Roland L. Pichon, Mark P. Pichon, Patrice Pichon Robinson, Tracy Pichon Baham, Veronica Pichon Joseph, and Cade Pichon Hagger are the children of Leon R. Pichon. 3 Donald Francis Rome is the widower of Elodie Rome. Inez Rome, Nathan Rome, and Marcella Rome Kliebert are the children of Elodie Rome. 4 Sally Becnel Tregre is the heir of Dano Becnel, deceased widower of Diane Becnel. Margaret Cortez Rome is the mother of Diane Becnel. 5 Fay Thibodeaux Danos is the widow of Golzie Danos. Julie Danos Landry, Jill Danos Trosclair, and Jana Danos Anzelmo are the children of Golzie Danos. -1-

2 Document Page 2 of 13 Sloan, Lana Dufrene Guidroz, Kyle Dufrene, Harold Dufrene, Billy-Jo Dufrene Toups, and 6 7 Corky Dufrene, Charlene Dufrene Faucheux, Kerney Savoie, Jr., and Joshua Savoie, Irene 8 Welsh Dufrene, and Neal Dufrene, Gwendolyn T. Ewing, Wilson Ewing, Terry Paul Ewing, 9 10 Rodney Ewing, and Christine Ewing, Branden Favre, Dorsie Galatas, Michael Galatas, Arnold 11 Galatas, Sandy Galatas, Shantel Johnson, Laura Miller, and Kawana Miller, Josie Legendre Granier, individually and on behalf of Benjamin Granier, and Jared Granier, Clint Granier, and Desiree Granier Dufrene, Shannon Herbert Diket, and Dale Anthony Herbert, Jr., Billy M. 6 Audie Dufrene, Leonelle Dufrene Sloan, Lana Dufrene Guidroz, Kyle Dufrene, Harold Dufrene, and Billy-Jo Dufrene Toups are the children of Gerald Dufrene. Corky Dufrene is the tutor and administrator of the estate of Tiffany Dufrene, daughter of Charmine Dufrene who is a deceased child of Gerald Dufrene. 7 Charlene Dufrene Faucheux is the widow of Steve Dufrene. Kerney Savoie, Jr., and Joshua Savoie are the adopted children of Steve Dufrene. 8 Irene Welsh Dufrene is the widow of Willard Dufrene. Neal Dufrene is the child of Willard Dufrene. 9 Gwendolyn T. Ewing is the widow of Murphy Ewing. Wilson Ewing, Terry Paul Ewing, Rodney Ewing, and Christine Ewing are the children of Murphy Ewing. 10 Branden Favre is the child of Linda Favre. 11 Dorsie Galatas is the widow of Joseph J. Galatas. Michael Galatas, Arnold Galatas, and Sandy Galatas are the children of Joseph J. Galatas. Shantel Johnson, Laura Miller, and Kawana Miller are the children of Joseph L. Galatas, deceased child of Joseph J. Galatas. 12 Josie Legendre Granier is the widow of Byron Granier. Benjamin Granier, Jared Granier, Clint Granier, and Desiree Granier Dufrene are the children of Byron Granier. Sr.. 13 Shannon Herbert Diket, and Dale Anthony Herbert, Jr. are the children of Dale Herbert, -2-

3 Document Page 3 of Jambon, and Bobby S. Jambon, Kenneth Kimberly, and Mary Kimberly, Clailee Aucoin 16 Landry, Jamie Landry, and Glen Landry, Ronald S. Millender, Jr. and Micheline D Lynne 17 Millender, Shirley Hebert Naquin, Annette Naquin Womer, Robin Naquin Mauduit, Kenneth P Naquin, Keith G. Naquin, and Bert C. Naquin, Jean Collings Simon, and Vernon Simon, Jr., Joan Walker, Jan Walker St. Pierre, Marc Walker, Todd Walker, Timothy Walker, Michael 20 Walker, and Rudy Walker, Jr., and Warren Winters, Jr., Wanita Winters, Jennifer Haywood, 21 Naomi Haywood Zimbro, and Jessica Haywood (hereinafter collectively Roussel & Clement Claimants ) move to permanently seal any and all Mesothelioma Claim Questionnaires and/or Supplemental Exposure Questionnaires regarding Dudley Marchand, Jr., Leon R. Pichon, Elodie 14 Billy M. Jambon, and Bobby S. Jambon are the children of Doris Jambon. 15 Kenneth Kimberly is the child of Lois Kimberly. Mary Kimberly is the widow of Wayne Kimberly, deceased child of Lois Kimberly. 16 Clailee Aucoin Landry is the widow of Raleigh Landry. Jamie Landry, and Glen Landry are the children of Raleigh Landry. 17 Ronald S. Millender, Jr. and Micheline D Lynne Millender are the children of Ronald S. Millender, Sr. 18 Shirley Hebert Naquin is the widow of Herbert Naquin. Annette Naquin Womer, Robin Naquin Mauduit, Kenneth P. Naquin, Keith G. Naquin, and Bert C. Naquin are the children of Herbert Naquin. 19 Jean Collings Simon is the widow of Vernon Simon, Sr. Vernon Simon, Jr. is the child of Vernon Simon, Sr. 20 Joan Walker is the widow of Rudy Walker, Sr. Jan Walker St. Pierre, Marc Walker, Todd Walker, Timothy Walker, Michael Walker, and Rudy Walker, Jr., are the children of Rudy Walker, Sr. 21 Warren Winters, Jr., and Wanita Winters are the children of Warren Winters. Jennifer Haywood, Naomi Haywood Zimbro, and Jessica Haywood are the children of Danielle Winters who is a deceased daughter of Warren Winters. -3-

4 Document Page 4 of 13 G. Rome, and any and all data produced by the Delaware Claims Processing Facility regarding the following individuals: Diane Becnel, Golzie Danos, Gerald Dufrene, Steve Dufrene, Willard Dufrene, Murphy Ewing, Linda Favre, Joseph J. Galatas, Byron Granier, Dale Herbert, Sr., Doris Jambon, Lois Kimberly, Raleigh Landry, Ronald Millender, Sr., Herbert Naquin, Vernon Simon, Sr., Rudy Walker, Sr., and Warren Winters, Sr. At the outset, the Roussel & Clement Claimants note that they supplied confidential settlement information in the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires with the understanding that the information supplied would remain sealed. The Roussel & Clement Claimants would not have supplied this information if they had known the information they were supplying would become accessible to the public for inspection. The Roussel & Clement Claimants will be prejudiced if the confidential information they supplied with the understanding that said information would remain under seal is unsealed and made available to the public for inspection. The Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility contain information relating to settlements entered into by the Roussel & Clement Claimants with trusts established to pay asbestos liabilities for former asbestos defendants, and with defendants in the tort system. Information regarding such settlements are clearly protected from disclosure under both federal and state law. Furthermore, allowing the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility regarding the Clients of Roussel & Clement to be available to the public for inspection would not only violate their rights under federal and state law but would also violate the strong public -4-

5 Document Page 5 of 13 policy, on both the national and state level, in favor of encouraging settlements. In Allison v. Goodyear Tire & Rubber Co., 2010 WL (E.D. Pa. August 19, 2010), the Eastern District of Pennsylvania the court handling the Multi District Litigation for all asbestos cases in federal court held that settlement documents, including statements of exposure contained in settlement releases executed by plaintiffs as to other defendants, are not discoverable. Allison, 2010 WL at 2-3 (E.D. Pa. August 19, 2010). In reaching its conclusion, the Allison Court noted that information regarding settlements and negotiations is inadmissible if offered to prove liability.... Id. at 1. The court ruled that settlement documents and bankruptcy trust information is not subject to discovery even if the settlement releases indicate statements of exposure. The court held that such would violate Rule 408 of the 22 Federal Rules of Evidence, which recognizes the strong public policy promoting settlement. The Court further held that the information is not even discoverable to use as impeachment evidence against a plaintiff. The view of the Eastern District of Pennsylvania has been echoed by other federal courts. For example, in Davis v. Johns-Manville Products, 1990 WL (E.D. La. October 16, 1990), the Eastern District of Louisiana held that the disclosure of settlements would not lead to the discovery of admissible evidence because such information would not prove liability, would not influence the amount of contribution to which a defendant may be entitled, and would not result in a reduction of a final judgment against the defendant. Id. at *1 (E.D. La. October 16, 1990). Furthermore, the trial court found that the defendant was not entitled to discover the 22 Similarly, Louisiana Code of Evidence Article 408, which is patterned on Rule 408 of the Federal Rules of Evidence, recognizes a strong public policy in favor of promoting settlements. -5-

6 Document Page 6 of 13 settlement agreements reached between the plaintiffs and the joint tortfeasor because such information is irrelevant. Id. at *1-2 (citing Martin v. American Petrofina, Inc., 779 F.2d 250 (5th Cir. 1985)). The Eastern District of Pennsylvania routinely refuses to allow parties to obtain information regarding the amounts plaintiffs have received from co-defendants or other potentially responsible parties, including settling asbestos trusts. See, e.g., Anderson v. Ford Motor Co., 2010 WL , at *1 (E.D. Pa. Oct. 20, 2010); Dent v. Westinghouse, 2010 WL 56054, at *1 (E.D. Pa. Jan. 4, 2010); Shepherd v. Pneumo-Abex, LLC, 2010 WL , at *2 (E.D. Pa. Aug. 30, 2010). Rule 408 of the Federal Rules of Evidence provides, in part, that evidence of a compromise of a claim, which is disputed as to either validity or amount, is not admissible to prove liability for or invalidity of the claim or its amount. The purpose of this rule is to prevent prejudice to the settling parties who may have settled in order to avoid litigation and to promote the public policy of encouraging compromise. Fed. R. Evid. 408, Notes of Advisory Committee on Proposed Rules, Belton v. Fibreboard Corporation, 724 F.2d 500 (5th Cir. 1984); McHann v. Firestone Tire & Rubber Co., 713 F.2d 161 (5th Cir. 1983). Furthermore, ample federal case law demonstrates that the courts should refuse to allow defendants to obtain information regarding the amounts claimants have received from other defendants, or potentially responsible parties, recognizing heightened discovery protections for settlement materials, and a public policy favoring the confidentiality of settlement-related communications. See, e.g., Block Drug Co. v. Sedona Labs., Inc., 2007 WL , at *1 (D. Del. Apr. 19, 2007) (heightened discovery standard applies to settlement materials); Matsushita Elecs. Corp. v. Loral Corp., 1995 WL , at *4 (S.D.N.Y. Sept. 7, 1995) (denying discovery -6-

7 Document Page 7 of 13 of settlement materials because requesting party must, as the price for obtaining such potentially disruptive disclosure, make a fairly compelling showing that it needs the information ); Riddell Sports, Inc. v. Brooks, 1995 WL 20260, at *1 (S.D.N.Y. Jan. 19, 1995) ( absent a particularized showing of their relation to admissible evidence, documents concerning settlement are presumed irrelevant and need not be produced ) (internal quotations omitted); In re N.Y. Cnty. Data Entry Worker Prod. Liab. Litig., 616 N.Y.S.2d 424, 427 (N.Y. Sup. Ct. 1994), aff d, 635 N.Y.S.2d 641 (N.Y. App. Div. 1995) (rejecting discovery of settlement agreements); Barbine v. Keystone Quality Transp., 2004 WL , at *1 (E.D. Pa. Apr. 16, 2004) ( As to the terms of the settlement agreement, we note that public policy strongly favors the settlement of disputed claims, and confidentiality agreements regarding settlements should not be set aside absent a compelling justification. ) (citation omitted); Butta-Brinkman v. FCA Int l, Ltd., 164 F.R.D. 475, (N.D. Ill. 1995) (determining upon a motion to compel that confidential settlement agreements reached in other cases were not to be disclosed because of the strong public policy in favor of maintaining the parties confidentiality). Public policy favors settlements in the tort system. Courts recognize that reasonable expectations of confidentiality are essential to promoting settlements and will deny a request for disclosure of a competitor s settlement agreement because of the chilling effect an order of disclosure of agreements entered into with the understanding of confidentiality would have on future settlement negotiations in other litigation. Gaull v. Wyeth Labs., Inc., 687 F. Supp. 77, 83 (S.D.N.Y. 1988). As the Second Circuit has stated, there is simply no legitimate public interest to be served by disclosing settlement agreements [and] the parties to the agreement are likely to have a compelling interest in keeping the settlement amount confidential.... Thus, absent -7-

8 Document Page 8 of 13 special circumstances, a court should honor confidentialities that are bargained-for elements of settlement agreements. See Grove Fresh Distribs., Inc. v. John Labatt Ltd., 888 F. Supp. 1427, 1441 (N.D. Ill. 1995), aff d, 134 F.3d 374 (7th Cir. 1998) (internal quotations omitted). As set forth above, the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility regarding the Roussel & Clement Claimants contains information regarding settlements entered into by the Roussel & Clement Claimants with bankruptcy trusts and defendants in the tort system. As such the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility are not discoverable and should remain under seal so as to preserve the confidentialities of the Roussel & Clement claimants. Furthermore, allowing the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility regarding the Clients of Roussel & Clement, to be available to the public for inspection would violate the strong public policy set forth in Federal Rule of Evidence 408 in favor of encouraging settlements. Just as important as federal law in this regard, are the laws of the State of Louisiana regarding the disclosure of settlement information and materials. The United States Supreme Court has made clear that filing for bankruptcy does not entitle a debtor to substitute a new legal regime to govern its liabilities: Bankruptcy courts are not authorized in the name of equity to make wholesale substitution of underlying law controlling the validity of creditors entitlements, but are limited to what the Bankruptcy Code itself provides. Raleigh v. Illinois Dep t of -8-

9 Document Page 9 of 13 Revenue, 530 U.S. 15, (2000). Louisiana Code of Evidence article 408, much like Rule 408 of the Federal Rules of Evidence, provides, in part, that evidence of a compromise of a claim, which is disputed as to either validity or amount, is not admissible to prove liability for or invalidity of the claim or its amount. Louisiana Code of Evidence Article 408 has been interpreted to mean that compromises and offers to compromise are generally not admissible. See, Fidelity Bank and Trust Co. v. Deutsch, Kerrigan and Stiles, 557 So.2d 991 (La. App. 4th Cir. 1990). Louisiana Code of Evidence Article 408 also prohibits disclosure of conduct or statements made in compromise negotiations. To allow the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility regarding the Clients of Roussel & Clement to be available to the public for inspection would have a deterring effect on settlements in asbestos litigation. Deterring settlements is directly contrary to Louisiana law. According to the Louisiana Supreme Court: [O]ur courts have repeatedly refused to implement jurisprudential rules which would reduce the plaintiffs' incentive to reach settlements with defendants without the need for trial. Raley v. Carter, 412 So.2d 1045, 1048 (La. 1982) (emphasis added). Furthermore, Louisiana Code of Civil Procedure Article 1422 outlines the scope of discovery as follows: Parties may obtain discovery regarding any matter, not privileged, which is relevant to the subject matter involved in the pending action..." (emphasis added). The party seeking discovery has the burden of proving that the information sought is within the -9-

10 Document Page 10 of 13 scope of Louisiana Code of Civil Procedure Article 1422 and is not privileged. Fuller v. Wal-Mart Stores, Inc., 519 So.2d 366 (La. App. 2 Cir. 1988); Rullan v. Adobbati, 674 So.2d 417 (La. App. 4th Cir. 1996). Louisiana Code of Civil Procedure Article 1422 does not allow for the discovery of privileged or irrelevant information. Therefore, a settlement document is not discoverable if it was privileged. Dutton v. Guste, 387 So.2d 630, (La. App. 1st Cir. 1980), rev'd on other grounds, 395 So.2d 683 (La. 1981). The basic reason for this privilege of admissibility is the policy danger of discouraging compromises, favored by laws, if they can be used adversely to the compromiser..." Broussard v. State Farm Mut. Auto. Ins. Co., 188 So.2d 111, 121 (La. App. 3d Cir. 1966), writ refused, 249 La. 713, 190 So.2d 233 (La. 1966), cert. denied, 386 U.S. 909, 87 S.Ct. 855, 17 L.Ed.2d 783 (1967). Additionally, Louisiana Code of Evidence Article 506 clearly establishes that documents covered under the attorney-client privilege are not subject to discovery under any circumstances. Andry v. State Farm Mutual Automobile Insurance, 659 So.2d 495 (La. 1994). Under Louisiana Code of Evidence Article 506 the attorney-client privilege clearly covers confidential settlement documents created at any time. A case on point is Terrance v. The Dow Chemical Company, et al., (La. App. 1 Cir. 9/14/07), 971 So.2d 1058, writ denied, (La. 12/14/07), 970 So.2d 534. In Terrance, the trial court refused to allow into evidence plaintiffs settlement with the Johns-Manville Trust Fund. Id The defendant, Exxon, argued that it should be allowed to rely upon the settlement documents to prove John-Manville s liability. Id. at p However, the court recognized that LSA-C.E. arts. 408 A and 413 prohibit settlement documents from being admitted into evidence as proof of liability. Id. The Court affirmed the trial court s ruling and -10-

11 Document Page 11 of 13 confirmed that Exxon was required to prove at trial that Johns-Manville negligently caused the plaintiffs damages. Id; citing Raley v. Carter, 412 So.2d 1045, 1046 (La. 1982). Similarly, in Hoerner v. Anco Insulations, Inc., (La. App. 4 Cir. 1/23/02), 812 So.2d 45, 76, writ denied, 819 So.2d 1023 So.2d 24 (La. 2002), the court held that the trial court was correct in not allowing evidence of plaintiffs settlement agreements with other defendants. As set forth above, the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility regarding the Roussel & Clement Claimants contain information regarding settlements entered into by the Roussel & Clement Claimants with bankruptcy trusts and defendants in the tort system. As such the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility are not discoverable and are protected by the attorney-client privilege found in Louisiana Code of Evidence Article 506. Furthermore, allowing the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility regarding the Clients of Roussel & Clement to be available to the public for inspection would violate the strong public policy in Louisiana encouraging settlements. Considering the fact that the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility regarding the Roussel & Clement Claimants contain confidential settlement information which is not discoverable, which is protected by the attorneyclient privilege, and that allowing this information to be made available to the public for -11-

12 Document Page 12 of 13 inspection would greatly deter settlements in asbestos litigation, the Roussel & Clement Claimants would not be protected by a partial redaction of the Mesothelioma Claim Questionnaires and Supplemental Exposure Questionnaires, and data produced by the Delaware Claims Processing Facility by the Delaware Claims Processing Facility. Accordingly, the Roussel & Clement Claimants respectively move to permanently seal any and all Mesothelioma Claim Questionnaires and/or Supplemental Exposure Questionnaires regarding Dudley Marchand, Jr., Leon R. Pichon, Elodie G. Rome, and any and all data produced by the Delaware Claims Processing Facility regarding the following individuals: Diane Becnel, Golzie Danos, Gerald Dufrene, Steve Dufrene, Willard Dufrene, Murphy Ewing, Linda Favre, Joseph J. Galatas, Byron Granier, Dale Herbert, Sr., Doris Jambon, Lois Kimberly, Raleigh Landry, Ronald Millender, Sr., Herbert Naquin, Vernon Simon, Sr., Rudy Walker, Sr., and Warren Winters, Sr. WHEREFORE, claimants, Bonnie A. Marchand, Patricia Marchand Picou, Dudley L. Marchand, III, Wayne M. Marchand, Rebecca Marchand Kennedy, Charmaine Marchand Bizette, and Brett L. Marchand, Jeanette Garnett Pichon, Roland L. Pichon, Mark P. Pichon, Patrice Pichon Robinson, Tracy Pichon Baham, Veronica Pichon Joseph, and Cade Pichon Hagger, Donald Francis Rome, individually and as curator on behalf of, Inez Rome, and Nathan Rome, Marcella Rome Kliebert, Sally Becnel Tregre, and Margaret Cortez Rome, Fay Thibodeaux Danos, Julie Danos Landry, Jill Danos Trosclair, and Jana Danos Anzelmo, Audie Dufrene, Leonelle Dufrene Sloan, Lana Dufrene Guidroz, Kyle Dufrene, Harold Dufrene, Billy-Jo Dufrene Toups, and Corky Dufrene, Charlene Dufrene Faucheux, Kerney Savoie, Jr., and Joshua Savoie, Irene Welsh Dufrene, and Neal Dufrene, Gwendolyn T. Ewing, Wilson Ewing, Terry Paul Ewing, Rodney Ewing, and Christine Ewing, Branden Favre, Dorsie Galatas, Michael Galatas, -12-

13 Document Page 13 of 13 Arnold Galatas, Sandy Galatas, Shantel Johnson, Laura Miller, and Kawana Miller, Josie Legendre Granier, individually and on behalf of Benjamin Granier, and Jared Granier, Clint Granier, and Desiree Granier Dufrene, Shannon Herbert Diket, and Dale Anthony Herbert, Jr., Billy M. Jambon, and Bobby S. Jambon, Kenneth Kimberly, and Mary Kimberly, Clailee Aucoin Landry, Jamie Landry, and Glen Landry, Ronald S. Millender, Jr. and Micheline D'Lynne Millender, Shirley Hebert Naquin, Annette Naquin Womer, Robin Naquin Mauduit, Kenneth P. Naquin, Keith G. Naquin, and Bert C. Naquin, Jean Collings Simon, and Vernon Simon, Jr., Joan Walker, Jan Walker St. Pierre, Marc Walker, Todd Walker, Timothy Walker, Michael Walker, and Rudy Walker, Jr., and Warren Winters, Jr., Wanita Winters, Jennifer Haywood, Naomi Haywood Zimbro, and Jessica Haywood, pray that the Roussel & Clement Claimants Motion to Seal be granted. CERTIFICATE OF SERVICE I hereby certify that a copy of the foregoing pleading has been served on all persons and entities listed on the most recent Updated Master Service List, and to counsel of record for the Public Access Proponents, th on this 4 day of September, S/ Gerolyn P. Roussel GEROLYN P. ROUSSEL Respectfully submitted, ROUSSEL & CLEMENT S/ Gerolyn P. Roussel GEROLYN P. ROUSSEL PERRY J. ROUSSEL, JR JONATHAN B. CLEMENT LAUREN R. CLEMENT BENJAMIN P. DINEHART DYLAN A. WADE Cannes Drive LaPlace, LA Telephone: (985) ATTORNEYS FOR CLAIMANTS -13-

14 Case Doc Filed 09/04/14 Entered 09/04/14 15:16:53 Desc Proposed Order Page 1 of 1 UNITED STATES BANKRUPTCY COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION IN RE: * CASE NO. 10-BK GARLOCK SEALING * CHAPTER 11 TECHNOLOGIES, LLC, ET AL., DEBTORS * JOINTLY ADMINISTERED ORDER Considering Roussel & Clement Claimants Motion to Seal, IT IS ORDERED that Roussel & Clement Claimants Motion to Seal is GRANTED. Charlotte, North Carolina, this day of, JUDGE -1-