Unethical Attorney Video Evidence

Can you help encounter and draft me this untheical attorney . She hasn’t pesented the video except one that is edited . This malfeance attorny is tell the judge she gave the evidence which is not true. And this shoplifing case was been disnisses and expunged which this video should not be on this civil matter case .DEFENDANT TARGET CORPORATION'S SUPPLEMENTAL BRIEF IN SUPPORT OF ITS EX PARTE MOTION TO FILE UNDER SEAL EXHIBITS "*", "*", "*", "*", **", **" AND "*" TO ITS MOTION FOR SUMMARY JUDGMENT NO. * RE: CLAIMS Defendant TARGET CORPORATION ("Target", by and through its attorneys, Yoshimoto Law Group, A Limited Liability Law Company, hereby files its Supplemental Brief in Support of its Ex Parte Motion to File Under Seal Exhibits "*, "*", "*", "**, "*", ** and "*" to its Motion for Summary Judgment No. * Re: Claims ("Motion to Seal"). This supplemental brief is filed pursuant to Court Order ECF * inviting Target to file a supplemental brief identifying compelling reasons to seal Exhibits "*", "*", "*", "*", "*", "*" and "*" in their entirety. With respect to video Exhibits "*" "*" and "*", Target asserts that allowing and fraudulent activities on the premises." Id. at **. The Court recognized the "general right to inspect and copy public records and documents, including judicial records and 'documents" stated under Kamakana v. City & Cnty. of Honolulu, * F.3d *, * (9th Cir. *). Id. However, the court stated that the presumption in favor of disclosure "is not absolute and can be overridden given sufficiently compelling reasons for doing so" and found good cause to seal. Id. Here, similarly the disclosure of the confidential locations and angles of Target's security cameras could be used by potential criminals. Target takes particular care to avoid disclosure of the locations of its cameras and the images captures by them, including using items that mimic the appearance of its cameras. Whether the public is able to see a security camera in a particular location as the nature of the imagesThe public release of the information contained in Exhibits "g", "*" and "*" are similarly confidential and open Target up to security risks. The photos in Exhibits "*" and "*" similarly reveal camera angles captured by Target security. The two exhibits also contain reference to the software used by Target to track theft and communicate internally. This software is a trade secret, proprietary to Target and give a competitive advantage over their competitors. Further, knowledge of the software could be exploited by potential hackers, creating an electronic security risk. Exhibits "*", "*" and "*" reveal the security and surveillance practices of Target, that could be used by potential criminals to avoid detection and detention. For example, having knowledge of the specific techniques used by Target security, a potential criminal would be able to pre-empt actions by Target security to detain rous nainio likelihood of further criminal actions at Target that could endanger the visiting public. For the foregoing reasons as well as those specified in Target's Motion to Seal, Target respectfully requests that the Court also seal Exhibits "*", "*", "g", "*", "*", "*" and "*" in their entirety. It is Target's position that the above exhibits should be sealed. However, if the Court should find that the exhibits may not be sealed in their entirety, at a minimum, Target proposes the following modifications in addition to the redactions mentioned by the Court: Exhibit * (redacted) and * (redacted): that references to Target's internal software and photos be redacted; * Target believes these redactions are necessary to protect proprietary information, the privacy of the minor children, and the safety of the public to the extent possible. DATED: Honolulu, Hawaii, September *, *. YOSHIMOTO LAW GROUP A Limited Liability Law Company /s/ Jason H. Fieman DONNA A.O. YOSHIMOTO JASON H. FIEMAN MAYA A. VANDRUNEN Attorneys for Defendant TARGET CORPORATION Are

Can help draft the motions