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UNITED STATES DISTRICT COURT 

SOUTHERN DISTRICT OF OHIO 

Wendy Berry, Lorri Hulings, and Kathleen 

Sammons, individually and as representatives of a 

class of similarly situated persons, and on behalf 

of the FirstGroup America, Inc. Retirement 

Savings Plan, 

Plaintiffs, 

v. 

FirstGroup America, Inc., FirstGroup 

America, Inc. Employee Benefits Committee, 

and Aon Hewitt Investment Consulting, Inc., 

Defendants. 

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Case No. 1:18-cv-00326-MWM 

Judge Matthew W. McFarland 

DEFENDANT AON HEWITT INVESTMENT CONSULTING INC.’S UNOPPOSED 

MOTION FOR LEAVE TO SEAL UNREDACTED VERSIONS OF DOCUMENTS 

FILED IN CONNECTION WITH FIRSTGROUP AMERICA INC.’S MOTION FOR 

SUMMARY JUDGMENT 

 

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Pursuant to Federal Rule of Civil Procedure 5.2(d) and Local Rule 5.2.1(a), Defendant 

Aon Hewitt Investment Consulting, Inc. (“AHIC”) hereby respectfully moves the Court for 

permission to file unredacted versions of the following transcripts and expert reports under seal: 

• Transcript of the Deposition of Clint Cary (“Cary Tr.”), ECF No. 103; 

• Transcript of the Deposition of Joan Boughton (“Boughton Tr.”), ECF No. 104; 

• Transcript of the Deposition of Drew McCorkle (“McCorkle Tr.”), ECF No. 105; 

• Transcript of the Deposition of Ryan Neff (“Neff Tr.”), ECF No. 106; 

• Transcript of the Deposition of Samuel Halpern, a redacted copy of which is attached 

as Exhibit A to the accompanying Declaration of William D. Pollak (“Pollak Decl.”)1; 

• Transcript of the Deposition of Brian Becker, a redacted copy is attached as Exhibit B 

to the Pollak Decl.; 

• Excerpts of the Expert Report of Samuel Halpern (“Halpern Rpt.”), Exhibit 59 to the 

Declaration of David Rosenberg, ECF 109 (“Rosenberg Decl.), a redacted version is 

attached as Exhibit C to the Pollak Decl.; and 

• Excerpts of the Expert Report of Brian Becker (“Becker Rpt.”), Exhibit 60 to the 

Rosenberg Decl., a redacted version is attached as Exhibit D to the Pollak Decl. 

As discussed further herein, there is good cause to file the unredacted versions of these 

transcripts and expert reports under seal because they reference certain highly sensitive and 

confidential information, including (i) information regarding the compensation or personal 

 1

 FirstGroup has already filed redacted versions of the transcripts of Drew McCorkle, Joan Boughton, Clint 

Cary, and Ryan Neff publicly. See ECF 103–106. AHIC has submitted redacted versions of the transcripts and 

expert reports of Brian Becker and Samuel Halpern with this motion as Exhibits A–D to the Pollak Decl. based on 

plaintiffs’ representation that they intend to withdraw their confidentiality designations over these documents. See 

Pollak Decl. ¶¶ 5–6. FirstGroup has also indicated that they do not intend on asserting that any portions of these 

documents contain FirstGroup’s confidential information. See ECF 110 at 2 n.1. 

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employment histories of current or former AHIC employees, (ii) information about AHIC’s other 

clients, who are non-parties to this litigation, (iii) AHIC’s confidential pricing of its services to 

customers or business development strategies, and (iv) AHIC’s proprietary strategy for 

constructing investments. The publication of this information could result in serious harm to 

AHIC or certain third parties (e.g., former AHIC employees and AHIC’s customers). 

AHIC’s sealing request is the most “narrowly tailored” means of protecting the privacy 

interests at stake because AHIC proposes limited and narrowly tailored redactions to these 

transcripts and expert reports. See Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 

299, 305 (6th Cir. 2016). Indeed, AHIC proposes to redact only portions of 66 pages out of 

1,498 total transcript pages (i.e., only 4%) and has limited its redactions to sensitive information. 

Moreover, AHIC has reached a settlement in principle with plaintiffs, ECF 94, and the 

information being redacted is largely irrelevant to FirstGroup America Inc.’s (“FirstGroup’s”) 

pending motion for summary judgment—in fact, none of the redacted transcript pages are cited 

by FirstGroup in its summary judgment motion or statement of undisputed facts. AHIC thus 

seeks to redact only information that is irrelevant to the pending motion and particularly 

sensitive. AHIC has conferred with plaintiffs and FirstGroup and they do not oppose the sealing 

of unredacted versions of these documents. Accordingly, AHIC respectfully requests that the 

Court grant AHIC’s motion to file the unredacted versions of these documents under seal. 

I. BACKGROUND 

On July 8, 2021, this Court entered the Stipulated Protective Order (ECF No. 65, the 

“Protective Order”). On May 13, 2022, Plaintiffs served the expert reports of Samuel Halpern 

and Brian Becker and designated them as Confidential under the Protective Order. These expert 

reports describe and quote directly from various documents produced by AHIC and designated 

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by AHIC as Confidential under the Protective Order. 

On October 12, 2022, Plaintiffs and AHIC jointly notified the Court that they had reached 

a settlement in principle of the claims against AHIC. ECF 94. On October 13, 2022, the Court 

granted a 60-day extension of the deadline for AHIC to file its summary judgment motion to 

facilitate the finalization of a possible settlement. On October 14, 2022, FirstGroup filed its 

motion for summary judgment. ECF 107. In support of its motion for summary judgment, 

FirstGroup filed the transcripts of the depositions of three former and one current employees of 

AHIC: Joan Boughton, Clint Cary, Ryan Neff, and Drew McCorkle. See ECF 103–106. To 

facilitate the public filing of these transcripts, AHIC significantly narrowed its prior 

confidentiality designations such that only very limited portions of these transcripts remained 

designated as Confidential under the Protective Order and FirstGroup filed redacted versions of 

these four transcripts on the public docket. On October 14, 2022, FirstGroup filed a motion to 

provisionally seal the unredacted versions of these transcripts, ECF 110. AHIC now moves to 

permanently seal the unredacted versions of the four transcripts that it designated as 

Confidential. 

In addition, in support of its motion for Summary Judgment, FirstGroup filed the 

transcripts of the depositions of plaintiffs’ experts Samuel Halpern and Brian Becker and 

excerpts of the expert reports of Samuel Halpern and Brian Becker as Exhibits 59–60 to the 

Rosenberg Decl. As these reports and transcripts had been designated as “Confidential” in 

whole or in part by Plaintiffs, FirstGroup filed these transcripts and expert reports under seal. 

See ECF 110. AHIC has subsequently conferred with plaintiffs and with FirstGroup and neither 

party intends to move to seal these reports and transcripts. Accordingly, AHIC has filed redacted 

versions of these transcripts and reports with this motion as Exhibits A–D of the Pollak Decl. and 

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now moves to seal the unredacted versions of these reports and transcripts. 

II. LEGAL STANDARD 

It is well established that it is appropriate to file documents under seal upon a showing of 

“good cause.” Fed.R.Civ.P. 26(c). The Sixth Circuit has held that motions to seal should be 

granted where (1) there are “compelling reasons” that justify the sealing of documents, (2) the 

“public interest” in access to the information sought to be sealed does not outweigh the privacy 

interests at stake, (3) the sealing request is “narrowly tailored,” and (4) there are no special 

considerations that counsel against sealing the information at issue. Shane Grp., Inc., 825 F.3d 

at 305–07. Courts routinely seal personal information of non-parties and proprietary business 

information pertaining to “confidential business interests.” United States v. Brown, 2022 WL 

1274411, at *2 (W.D. Ky. Apr. 28, 2022); NFocus Consulting Inc. v. Uhl, 2020 WL 12687859, 

at *2 (S.D. Ohio Dec. 29, 2020). Courts are particularly likely to grant sealing where the moving 

party has applied limited redactions designed to preserve public access to the relevant 

information. Shane Grp., 825 F.3d at 305; United States ex rel. Scott v. Humana Inc., 2021 WL 

4449277, at *6 (W.D. Ky. Sept. 28, 2021); Proctor & Gamble Co. v. Ranir, LLC, 2017 WL 

3537195, at *3 (S.D. Ohio Aug. 17, 2017). 

III. ARGUMENT 

A. Compensation and Employment Information of Current or Former AHIC 

Employees 

1. AHIC has redacted confidential information regarding the compensation and 

employment histories of certain current and former AHIC employees in Cary Tr., ECF No. 103, 

at PAGEID 3189–3198, 3201, 3303–3305, 3379–3386, Boughton Tr., ECF No. 104, at PAGEID 

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3471–3474, 3478, 3479–3481, 35082, McCorkle Tr., ECF No. 105, at PAGEID 3806–3811, 

3919–3931, Neff Tr., ECF No. 106, at PAGEID 4096–4100, and Pollak Decl. Ex. A, Halpern Tr. 

at 182.3 The redacted testimony discusses (i) employment actions (e.g., termination, demotion, 

or promotion) of AHIC employees and (ii) the compensation awarded to certain current and 

former AHIC employees and/or the means of determining that compensation. 

2. AHIC respectfully submits that sealing the unredacted versions of these 

transcripts is appropriate and necessary because the personal information contained within the 

redactions is extremely sensitive. See Veritas Independent Partners LLC v. Ohio Nat’l Life Ins. 

Co., 2022 WL 1749024, at *3 (S.D. Ohio Jan. 4, 2022) (granting request to seal documents 

reflecting compensation information); Brown, 2022 WL 1274411, at *2 (“[d]istrict courts 

regularly find good cause exists for allowing redactions in court filings in order to 

protect personal identifying information”) (quotation omitted; alteration in original); Caudill 

Seed & Warehouse Company, Inc. v. Jarrow Formulas, Inc., 2019 WL 1795941, at *3 (W.D. 

Ky. Apr. 24, 2019) (granting request to seal testimony regarding employee salaries). 

3. The public disclosure of this information could harm both AHIC and its current 

and former employees. This testimony is highly sensitive and personal for the former AHIC 

employees identified in the transcripts and could cause them professional harm if disclosed. In 

addition, AHIC’s approach to compensating, retaining, and disciplining its own employees is 

 2

 In addition, the references to witnesses home addresses in Cary Tr., ECF No. 103, at PAGEID 3274 and 

Boughton Tr., ECF No. 104, at PAGEID 3460 have been redacted because these pages reveal confidential personal 

identifiable information that is irrelevant to the litigation. See e.g., Ewalt v. GateHouse Media Ohio Holding II, Inc., 

2021 WL 4841064, at *2 (S.D. Ohio Oct. 18, 2021) (granting request to seal home addresses and other private 

personal information). 

3

 As noted, the Halpern and Becker transcripts have already been filed under seal by FirstGroup in unredacted 

form (which FirstGroup has provisionally moved to seal). Exhibits A-B to the Pollak Decl. are unredacted versions 

of these transcripts. 

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competitively sensitive information that could harm AHIC if disclosed. 

4. This information is also irrelevant to FirstGroup’s pending motion for Summary 

Judgment and, thus, there is no countervailing public interest in access to this sensitive personal 

information. See generally Heraeus Kulzer, GmbH v. Biomet, Inc., 881 F.3d 550, 566–67 (7th 

Cir. 2018) (quoting Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544, 548 (7th Cir. 2002)) (noting 

that the interest in public access only applies to “materials that form the basis of the parties’ 

dispute and the district court’s resolution”). AHIC proposes very limited redactions to these 

transcripts to seal only those pages that discuss employee compensation and employee actions 

while preserving public access to those portions of these transcripts that are relevant to the 

pending summary judgment motion. NorCal Tea Party Patriots v. Internal Revenue Serv., 2022 

WL 1316267, at *6 (S.D. Ohio, May 3, 2022) (granting request to seal information related to 

parties not involved in litigation and concerning incidents “hav[ing] no bearing on the merits of 

the underlying case”). These limited redactions ensure that FirstGroup’s filings remain public to 

the greatest extent possible while still protecting AHIC’s and its former employees’ legitimate 

privacy interests 

B. Third Party Confidential Information 

5. The redactions in Cary Tr., ECF No. 103, at PAGEID 3289, 3290, 3301, 3338, 

3363, 3366, 3367, 3377, Boughton Tr., ECF No. 104, at PAGEID 3500–3501, McCorkle Tr., 

ECF No. 105, at PAGEID 3817–3819, Neff Tr., ECF No. 106, at PAGEID 4050, Pollak Decl. 

Ex. A, Halpern Tr. at 119, Ex. B, Becker Tr. at 76–77, 144, 158–59, and Rosenberg Decl., Ex. 

60, Becker Report, ECF No. 109–66, at 21 (filed in redacted version as Pollak Decl. Ex. D)4

 4

 FirstGroup previously filed unredacted versions of the Halpern and Becker expert reports as Exhibits 59–60 to 

the Rosenberg Decl. AHIC now attaches redacted versions of these documents as Exhibits C–D to the Pollak Decl. 

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concern the confidential information of certain third party clients and customers of AHIC, 

including their confidential investment strategies, specific strategic priorities, and detailed 

information regarding their investment decisions. The confidential information of other AHIC 

clients is not relevant to the issues in this litigation or the issues raised in FirstGroup’s summary 

judgment motion and could cause both AHIC and these innocent third parties unnecessary harm 

if disclosed publicly. 

6. Sealing these limited pieces of testimony is thus appropriate and necessary 

because of the confidential third party information discussed therein. See Shane Grp., 825 F.3d 

at 308 (“the privacy interests of innocent third parties should weigh heavily in a court's balancing 

equation”) (quoting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995); see also In re 

Knoxville News Sentinel Co., 723 F.2d 470, 477 (1983) (“individuals protected by the closure 

order here are third parties who were not responsible for the initiation of the underlying 

litigation. These individuals possessed a justifiable expectation of privacy that their names and 

financial records not be revealed to the public. Their interests in privacy are sufficiently 

compelling to justify non-disclosure”). 

7. AHIC’s clients justifiably expected that their sensitive investment strategies and 

priorities would remain confidential when they provided that information to AHIC. The public 

disclosure of the confidential investment strategies and investment priorities of AHIC’s other 

clients could negatively impact these innocent third parties and it will also harm AHIC’s ongoing 

relationships with its current and prospective clients. To avoid these negative consequences, 

AHIC proposes very limited redactions to these transcripts to remove discrete references to these 

third parties’ names while preserving public access to the information relevant to FirstGroup’s 

motion for summary judgment. 

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C. Confidential Pricing Information and Business Development Strategies 

8. AHIC has also redacted testimony regarding the fees that it charges its clients for 

its services and its confidential business development strategies in Cary Tr., ECF No. 103, at 

PAGEID 3214–3215, 3221–3222, 3224–3225, 3302, 3336, Boughton Tr., ECF No. 104, at 

PAGEID 3614, McCorkle Tr., ECF No. 105, at PAGEID 3755, 3757–3759, 3766–3767, Neff 

Tr., ECF No. 106, at PAGEID 4032–4033, 4050, Pollak Decl. Ex. A, Halpern Tr. at 169–70, 

Rosenberg Decl., Ex. 59, Halpern Report, ECF No. 109–65, at ¶¶ 134 (filed in redacted version 

as Pollak Decl. Ex C), Rosenberg Decl., Ex. 60, Becker Report, ECF No. 109–66, at 25 (filed in 

redacted version as Pollak Decl. Ex D). These redactions concern confidential information 

regarding (i) the confidential pricing and terms under which AHIC provided professional 

investment-related services to FirstGroup, (ii) AHIC’s confidential responses as part of a 

competitive request for proposal (“RFP”) process, and (iii) AHIC’s confidential strategies for 

business development. Each of these categories of information is protected by AHIC and 

maintained as confidential by AHIC in the regular course of business, as well as pursuant to the 

confidentiality provision of AHIC’s most recent Investment Management Agreements with 

FirstGroup. 

9. Courts routinely permit confidential pricing information and business 

development strategies like that contained in these redacted excerpts of testimony to be filed 

under seal. See, e.g., Ranir, LLC, 2017 WL 3537195, at *3–4 (P&G’s pricing strategy and 

marketing strategy should be redacted as public disclosure would allow competitors to have an 

“inside look” into P&G's business strategies); see also Kentucky v. Marathon Petroleum Co. LP, 

2018 WL 3130945, at *6 (W.D. Ky. June 26, 2018) (sealing “documents [that] reveal the 

‘terms, prices, and volume’ that [] third parties with whom [defendant] negotiated the deals 

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would be willing to accept in the operative market.”); In re Skelaxin (Metaxalone) Antitrust 

Litig., 2015 WL 1486709, at *2 (E.D. Tenn. Mar. 31, 2015) (sealing pricing data); McClure v. 

Allegheny Energy, Inc., 2008 WL 11380062, at *1 (S.D. W.Va. Oct. 23, 2008) (sealing “pricing 

information, which . . . could be used by competitors to gain an unfair business advantage in 

future negotiations”).5

10. As these courts have recognized, the public disclosure of a company’s pricing 

information and business development strategies can cause competitive harm. Indeed, public 

disclosure of AHIC’s pricing could harm AHIC’s relationships with other clients that do not 

receive as favorable pricing and place AHIC at a disadvantage in future competitive bidding 

processes. Similarly, AHIC’s business development strategies and the details of AHIC’s 

responses to an RFP is competitively sensitive information. AHIC accordingly respectfully 

submits that there are compelling justifications for these redactions. Moreover, testimony 

regarding AHIC’s business development strategies and pricing has no relevance to the litigation, 

now that AHIC has reached a preliminary settlement with plaintiffs. See generally Heraeus 

Kulzer, GmbH, 881 F.3d at 566–67 (quoting Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544, 548 

(7th Cir. 2002)) (noting that the presumption of public access only applies to “materials that form 

the basis of the parties’ dispute and the district court’s resolution”). 

11. Accordingly, AHIC respectfully submits that these redactions are narrowly 

 5 See also, e.g., Playtex Prods., LLC v. Munchkin, Inc., 2016 WL 1276450, at *11–12 (S.D.N.Y. Mar. 29, 2016) 

(sealing portions of a summary judgment brief discussing “confidential and sensitive business information, 

including sales and costs information” not found in the public record); TVIIM, LLC v. McAfee, Inc., 2015 WL 

4448022, at *3 (N.D. Cal. July 19, 2015) (sealing documents that “contain confidential product pricing information . 

. . [that, if disclosed,] would allow [the defendants’] competitors and suppliers to ‘take advantage of this information 

in negotiating pricing information,’ and allow its competitors to ‘gain an unfair advantage by using it to determine 

which features of its own products it could further develop and improve in order to gain market share’ over 

[d]efendant”); TriQuint Semiconductor, Inc. v. Avago Techs. Ltd., 2011 WL 6182346, at *6 (D. Ariz. Dec. 13, 2011) 

(sealing “pricing information [that, if disclosed,] would harm [Plaintiff’s] competitive standing”); ATI Indus. 

Automation, Inc. v. Applied Robotics, Inc., 801 F. Supp. 2d 419, 427 (M.D.N.C. 2011) (same). 

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tailored to protect AHIC’s privacy interests while preserving public access to the information 

relevant to the litigation. 

D. Proprietary Investment Strategies 

12. The redactions in Cary Tr., ECF No. 103, at PAGEID 3274–3275, Boughton Tr., 

ECF No. 104, at PAGEID 3495, 3583–3585, McCorkle Tr., ECF No. 105, at PAGEID 3850–

3851, 3868–3875, 3880, Neff Tr., ECF No. 106, at PAGEID 4036–4037, 4040–4041, 4046–

4047, 4055–4056, 4059, 4062–4063, 4073–4074, 4077–4079, 4081, 4083–4085, 4087, 4089–

4090, Pollak Decl. Ex. A, Halpern Tr. 192–93, 197–99, 204, 239, 246–47, 251, and Rosenberg 

Decl. Ex. 59, Halpern Report, ECF No. 109–65, at ¶¶ 68, 113, 125 (filed with redactions as 

Pollak Decl. Ex. C) relate to AHIC’s investment strategies and sensitive proprietary analyses 

regarding the design of investment products. In particular, this testimony discusses (i) AHIC’s 

strategy and processes for constructing investment products and the rationales supporting certain 

decisions, (ii) internal analyses of the performance of those investment products and possible 

changes in light of evolving market conditions, (iii) the costs associated with different 

investment structures, and (iv) AHIC’s confidential negotiations with third party investment 

managers. In addition, the Halpern Report directly quotes from internal AHIC strategic 

discussions that reveal AHIC’s proprietary thinking and strategies. As an investment advisor and 

delegated fiduciary, these materials are a key element of the value that AHIC provides to clients 

and their public disclosure would harm AHIC’s business interests. 

13. Sealing these exhibits is thus appropriate and necessary because of the proprietary 

and sensitive information contained therein. “Courts have recognized that a litigant’s interest in 

protecting sensitive business information whose disclosure could result in competitive 

disadvantage can be sufficient to support sealing.” Duff v. Centene Corp., 2022 WL 3151889, at 

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*2 (S.D. Ohio Aug. 8, 2022); see also Morris v. Tyson Chicken, Inc., 2020 WL 3442177, at *2 

(W.D. Ky. June 23, 2020) (sealing “confidential business information that could harm 

[defendant's] competitive standing”); Ethicon Endo-Surgery, Inc. v. Covidien, Inc., 2017 WL 

4168290, at *2 (S.D. Ohio Sept. 20, 2017) (recognizing interest in sealing “confidential 

information that would otherwise allow competitors an inside look at a company's business 

strategies”). 

14. The harm to AHIC and its third party clients that would result from disclosing this 

confidential information outweighs any public interest in the information. Sealing this 

information is also the most narrowly tailored means of protecting the privacy interests at stake 

because AHIC proposes very limited redactions to the testimony, covering only the proprietary 

investment strategies described above. These limited redactions ensure that Defendant’s filings 

remain publicly viewable on the docket to the greatest extent possible while still protecting 

AHIC’s legitimate privacy interests. See Hedick v. Kraft Heinz Co., 2019 WL 4958238, at *13 

(N.D. Ill. Oct. 8, 2019) (It is well established that parties may move to seal documents in order to 

“protect investment strategies beyond strategies that are common industry knowledge.”); ABS 

Glob., Inc. v. Inguran, LLC, 2017 WL 3588290, at *2 (W.D. Wis. Apr. 15, 2017) (finding that 

party had shown good cause to seal exhibits “which contain confidential information about [the 

party’s] business strategy.”); Johnson v. Allstate Ins. Co., 2008 WL 4279992, at *3 (S.D. Ill. 

Sept. 17, 2008) (finding good cause to seal documents reflecting “research and methodology” 

when “[t]he release of such material at this point has the potential to commercially harm [the 

party] and undermine the hefty monetary investment it has already placed in developing the 

data.”). 

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IV. CONCLUSION 

For the foregoing reasons, AHIC respectfully requests that this Court grant its motion to 

maintain under seal unredacted versions of ECF Nos. 103 – 106, Exhibits 59–60 to the 

Rosenberg Decl., and the transcripts of the depositions of Samuel Halpern and Brian Becker. 

Pursuant to S.D. Ohio Civ. R. 7.3(b), AHIC has conferred with Plaintiff and FirstGroup 

regarding this Motion to Seal and this motion is unopposed. 

Dated: October 20, 2022 Respectfully submitted,

/s/ Shannon M. Barrett 

Brian Boyle (pro hac vice) 

Shannon M. Barrett (pro hac vice) 

O’MELVENY & MYERS LLP 

1625 Eye St., NW 

Washington, DC 20006 

Telephone: (202) 383-5300 

Fax: (202) 383-5414 

bboyle@omm.com 

sbarrett@omm.com 

Stuart M. Sarnoff (pro hac vice) 

William Pollak (pro hac vice) 

O’MELVENY & MYERS LLP 

Times Square Tower 

7 Times Square 

New York, NY 10036 

Telephone: (212) 728-5675 

Fax: (212) 326-2061 

ssarnoff@omm.com 

wpollak@omm.com 

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V. Brandon McGrath (0072057) 

BINGHAM GREENEBAUM DOLL LLP 

2350 First Financial Center 

255 East Fifth Street 

Cincinnati, Ohio 45202-4728 

Telephone: 513-455-7641 

Brandon.mcgrath@dentons.com

Attorneys for Aon Hewitt Investment Consulting, 

Inc. (f/k/a Aon Hewitt Investment Consulting, 

Inc.) 

 

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CERTIFICATION REGARDING COMPLIANCE WITH LOCAL RULE 7.3(B) 

The undersigned counsel for Defendant Aon Hewitt Investment Consulting, Inc. 

pursuant to Local Rule 7.3(b), hereby certifies that on October 17, 19, and 20, 2022, he 

met and conferred with counsel for Plaintiffs and counsel for FirstGroup by email, both 

of whom confirmed that they do not oppose this Motion to Seal. 

Dated: October 20, 2022 s/ Shannon M. Barrett 

 Shannon M. Barrett (pro hac vice) 

Attorneys for Defendant Aon Hewitt 

Investment Consulting, Inc. (n/k/a Aon 

Investments USA, Inc.)

 

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CERTIFICATE OF SERVICE 

 I, Shannon M. Barrett, hereby certify that this document was served on all counsel of 

record via the Court’s ECF system on October 20, 2022. 

Dated: October 20, 2022 s/ Shannon M. Barrett 

 Shannon M. Barrett 

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