Banks v. McGynn, Hays & Co., Inc.

Opinion

IY] LAW OFFICES OF LAURIE E. MORRISON 100 Church Street, 8th Floor 28 Valley Road, Suite #1 October 11, 2022 New York, New York 10007 Montclair, New Jersey 07042 Phone: (212) 721-4051 VIA ECF Cell: (646) 457-8347 TT morrison@lemorrisonlaw.com Hon. Jennifer L. Rochon, U.S.D_J. United States District Court, SDNY 500 Pearl Street, Courtroom: 20B Chambers Room 1920 New York, NY 10007 Aisha Bams, Courtroom Deputy: 212-805-0204

RE: Edward Banks v. McGlynn, Hays & Co., Inc. et al. Consolidated Cases Civ. Action Nos.: 19-cv-05727, 21-cv-00679 (JLR) (RWL) Dear Hon. Rochon: In accordance with Your Honor’s October 7" Directive (Dkt. 106, 372), with Rule 1(A) of Your Honor’s Individual Rules, and with the SDNY’s Standing Order, 19-MC-00583, and Section 6 of the ECF Rules & Instructions (which were incorporated by reference therein), Plaintiffs counsel respectfully submits this motion to file the unredacted version of this letter and supporting medical record ex parte under seal, as the documents contain counsel’s highly sensitive and confidential medical/health information that would be intended for the Court’s Eyes Only. The documents request remote appearances by Plaintiffs counsel for medical/health reasons. Lugosch v. Pyramid Co. of Onondaga County, 435 F.3d 110 (2d Cir. 2006) would also arguably not apply, as counsel’s information is plainly irrelevant to the underlying claims and/or defenses asserted in the instant case and it would not otherwise be considered judicial documents/records, so the common law presumption of public access would not attach.

LAW OFFICES OF LAURIE E. MORRISON Page 2 of 2

Plaintiffs counsel thanks the Court for its time and consideration.

Respectfully Submitted,

Laurie E. Morrison, Esq.

Request GRANTED. Plaintiff's letter (ECF No. 108 in docket 21-cv-00679 and ECF No. 374 in docket 21-cv-00679) and the redacted portions of Plaintiff's letter-motion (ECF No. 373 in docket 19-cv-05727 and ECF No. 107 in docket 21-cv-00679) shall hereby remain sealed and under ex-parte view only. Dated: October 12, 2022 New York, New York ORDERED ZL J IFER(L/ROCHON ted States District Judge