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CARLOTTA PERKINS-MARTIN Plaintiff, v. ALL FOR YOU JANITORIAL, INC., et al. Defendants.

JUDGE GAUGHAN

DEFENDANTS' MOTION FOR LEAVE TO FILE JOINT MOTION
FOR APPROVAL AND CONFIDENTIAL JOINT STIPULATION OF SETTLEMENT UNDER SEAL

Now come Defendants, by and through counsel, and pursuant to Local Rule 5.2, respectfully move this Court for leave to allow the Parties to file their Joint Motion for Approval of Settlement, and Confidential Joint Stipulation of Settlement and Release, under seal with the Court. The grounds justifying the requested relief are set forth in the accompanying memorandum.

Anthony J. Lazzaro (0077962)


The Lazzaro Law Firm, LLC


920 Rockefeller Building


614 W. Superior Avenue


Cleveland, Ohio 44113


Attorney for Defendants


Steven A. Sindell (0002508)


Rachel Sindell (0078463)


Sindell and Sindell, LLP


Chagrin Plaza West


23611 Chagrin Blvd., Suite 227


Cleveland, Ohio 44122


Attorneys for Defendants


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Perkins-Martin v. All for You Janitorial, Inc.
(Jan 27, 2012)