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[PROPOSED] ORDER GRANTING SCHWAB’S MOTION TO FILE UNDER SEAL

No. 08-cv-01510 WHA

sf-2815807

DARRYL P. RAINS (CA SBN 104802)

EUGENE ILLOVSKY (CA SBN 117892)

MORRISON & FOERSTER LLP

755 Page Mill Road

Palo Alto, California 94304-1018

Telephone: 650.813.5600

Facsimile: 650.494.0792

Email: DRains@mofo.com

CRAIG D. MARTIN (CA SBN 168195)

DOROTHY L. FERNANDEZ (CA SBN 184266)

MORRISON & FOERSTER LLP

425 Market Street

San Francisco, California 94105-2482

Telephone: 415.268.7000

Facsimile: 415.268.7522

Attorneys for defendants The Charles Schwab Corporation, 

Charles Schwab & Co., Inc., Charles Schwab Investment 

Management, Inc., Schwab Investments, Charles R. Schwab, 

Evelyn Dilsaver, Randall W. Merk, George Pereira, Matthew 

Hastings, Mariann Byerwalter, Donald F. Dorward, William A. 

Hasler, Robert G. Holmes, Gerald B. Smith, Donald R. 

Stephens, and Michael W. Wilsey 

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

IN RE CHARLES SCHWAB CORP. 

SECURITIES LITIGATION

Master File No. C-08-01510-WHA

CLASS ACTION

[PROPOSED] ORDER GRANTING 

SCHWAB’S MOTION TO FILE 

UNDER SEAL 

Judge: Hon. William H. Alsup

Case 3:08-cv-01510-WHA Document 559 Filed 04/02/10 Page 1 of 2
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[PROPOSED] ORDER GRANTING SCHWAB’S MOTION TO FILE UNDER SEAL

No. 08-cv-01510 WHA

sf-2815807

On March 25, 2010, Schwab filed an administrative motion to seal certain materials filed 

in connection with its opposition to the Union Mission’s Motion to Extend Time for Exclusion 

from Class Membership (“Opposition”). Schwab moved to seal exhibits 4–15 of the Declaration 

of Dorothy L. Fernandez in support of the Opposition, as well as portions of its Opposition and 

portions of the supporting declarations of Laura Carnero, Mila Dunn, and Dorothy L. Fernandez. 

In support of its administrative motion to seal, Schwab filed a declaration attesting to the 

confidentiality of these materials which Schwab either redacted or filed under seal in their 

entirety. 

The Court finds that Schwab customers have a reasonable expectation of privacy in the 

types of information reflected in exhibits 4–15 to the Fernandez declaration, which includes 

account balances and investment positions. These documents include non-public information 

about Schwab customers who are not parties to this litigation. The information reflected in these 

exhibits, and the corresponding portions of the Opposition and declarations, is highly sensitive, 

personal, and confidential. 

It is hereby ordered that exhibits 4–15 of the Fernandez declaration, as well as the 

corresponding portions of the Opposition, Carnero declaration, Dunn declaration, and Fernandez 

declaration be SEALED. 

IT IS SO ORDERED.

DATED: _________________, 2010

HONORABLE WILLIAM H. ALSUP

UNITED STATES DISTRICT COURT JUDGE

April 1

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

IT IS SO ORDERED

Judge William Alsup

Case 3:08-cv-01510-WHA Document 559 Filed 04/02/10 Page 2 of 2