Robert A. Mittelstaedt (State Bar No. 60359) JONES DAY 555 California Sireet, 26th Floor San Francisco, CA 94104 Telephone: +1.415.626.3939 Facsimile: +1.415.875.5700 Email: Liat L. Yarnini (State Bar No. 251238) .1 ONES DAY 555 South Flowe? Street, 50th Floor Los Angeles CA 90071 Telephone: +1.213.489.3939 Facsimile: ?213.243.2539 Email: lvamini?z?oneedaycom Attorneys for Defendani; ELECTRONIC-ALLY FILED Superior Court of California, County of San Francisco 06 I 26/ 2018 Clerk of the Court WU Deputy Clerk SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SAN FRANCISCO WENDY MOORE, On Behalf of Herself and Othee Aggrieved Employees, Plaintiff, V. JONES DAY, and DOES 1-100, Defendant. CASE NO. MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF EX PARTE APPLICATION FOR AN ORDER SHORTENING TIME TO HEAR MOTION TO SEAL RECORD Date: June 26, 2018 Time: 11:00 am. Dept: 302 Judge: Hon. Harold Kahn Complaint Filed: June 19, 2018 MEMORANDUM ISO APPLICATION TO SHORTEN TIME Under Code of Civil Procedure section 1005(b), the court may prescribe a shorter time for serving motions and supporting and opposing papers than provided by section 1005. To the same effect, California Rules of Court 3.1300(b) provides that the conrt on its own motion or an application for an order shortening time supported by a declaration showing good cause may prescribe a shorter time than provided by section 1005. As shown in the accompanying declaration by Robert Mittelstaedt, good cause exists for this ex parte application to shorten time for Jones Day?s motion to sea! the record in this proceeding The complaint in this action was filed by a former Jones Day partner. The filing of the complaint violates the Partnership Agreement signed by the former partner in multiple respects) which will be detailed in the motion to seal. The litigation was accompanied by press coverage generated by plaintiff? counsel who issued an in?ammatory press release. Mittelstaedt Decl., Exhibit A. Plaintiff has no legitimate reason for her conduct which. has the inevitable effect of banning Jones Day. Given the high. likelihood of harm, it is essential for the complaint to be sealed as soon as possible. Hence, Jones Day seeks on an ex parte basis to shorten time for hearing its motion to seal. Jones Day proposes to file its motion to seat and supporting papers by the close of business today, with plaintiff?s response due by close of business Friday, June 29, and Jones Day?s reply by Monday, July 2, with a hearing to be set as soon as the Court can hear the matter. Dated: June 26, 2018 Jones Day By: Robert A. Mittelstaedt Robert A. Mittelstaedt Attorneys for Defendant NAi?l 503924700v1 2 MEMORANDUM ISO APPLICATION TO SHORTEN TIME