Doolittle v. Bloomberg L.P.

S.D. New York

Doolittle v. Bloomberg L.P.

DecidedApril 22, 2024

Docket1:22-cv-09136

StatusUnknown

This text of Doolittle v. Bloomberg L.P. (Doolittle v. Bloomberg L.P.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Doolittle v. Bloomberg L.P., (S.D.N.Y. 2024).

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April 12, 2024 VIA ECF

Hon. Jennifer L. Rochon, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street, Room 1920 New York, New York 10007

Re: Abigail Doolittle v. Bloomberg L.P., et al., Civil. Action No. 22-cv-09136 (JLR) Dear Judge Rochon, Pursuant to Rule 4Bi of Your Honor’s Individual Practices, Standing Order 19-MC-00583, and Section 6 of the Southern District of New York Electronic Case Filing Rules & Instructions, we write on behalf of Defendant Mark Crumpton to seek leave to file under seal unredacted versions of the Memorandum of Law filed in support of Mr. Crumpton’s motion for protective order (ECF No. 64-1) Declaration of Dr. Mamatha Gadarla (ECF No. 64-2), Declaration of Dr. Edward Vecchione (ECF No. 64-3), Declaration of Steve Crumpton (ECF No. 64-4), Declaration of Anna Aguilar (ECF No. 64-5), all of which were filed today in redacted form. Each of these documents contains sensitive medical information, as set forth in the SDNY ECF Privacy Policy, regarding Mr. Crumpton. While Rule 4Bi of Your Honor’s Individual Practices suggests that Court approval is not required to seal or redact such sensitive medical information, the e-filing system appears to require a letter motion seeking approval to submit a sealed filing. As such, Mr. Crumpton respectfully requests that the Court grant him leave to file the aforementioned papers under seal. is GRANTED. Although the common law right of public access to judicial "is firmly rooted in our nation's history," this right is not absolute and courts balance competing considerations against" the presumption of access. Lugosch v. Sincerely Co. of Onondaga, 435 F.3d 110, 119-20 (3d Cir. 2006) (quotation marks and , omitted); see Nixon v. Warner Commce'ns, Inc., 435 U.S. 589, 599 (1978) ("[T]he . as to access is one best left to the sound discretion of the trial court, a discretion to Anna Ag uilar in light of the relevant facts and circumstances of the particular case."). There strong privacy interest in the confidentiality of medical records. See Parker v. Brann, Anna Aguilar 12-cv-09408 (LIL) (SDA), 2022 WL 18402115, at *8 (S.D.N.Y. Dec. 17, 2022). it is appropriate here that unredacted versions of the memorandum at law and exhibits be filed under seal. of Court is respectfully directed to close the motion at ECF No. 65 and to ntain ECF Nos. 66-70 under seal. SO ORDERED. ONDA A) “4 =6f2P a“

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5 Penn Plaza, 19th Floor A | A B 171 East Ridgewood Ave, Ste. 201 New York, New York 10001 G U l R ENTLEY Ridgewood, New Jersey 07450 @ 212.835.1521 www.aguilarbentley.com @ 212.835.1521

April 12, 2024 VIA ECF

Hon. Jennifer L. Rochon, U.S.D.J. United States District Court Southern District of New York 500 Pearl Street, Room 1920 New York, New York 10007

Re: Abigail Doolittle v. Bloomberg L.P., et al., Civil. Action No. 22-cv-09136 (JLR) Dear Judge Rochon, Pursuant to Rule 4Bi of Your Honor’s Individual Practices, Standing Order 19-MC-00583, and Section 6 of the Southern District of New York Electronic Case Filing Rules & Instructions, we write on behalf of Defendant Mark Crumpton to seek leave to file under seal unredacted versions of the Memorandum of Law filed in support of Mr. Crumpton’s motion for protective order (ECF No. 64-1) Declaration of Dr. Mamatha Gadarla (ECF No. 64-2), Declaration of Dr. Edward Vecchione (ECF No. 64-3), Declaration of Steve Crumpton (ECF No. 64-4), Declaration of Anna Aguilar (ECF No. 64-5), all of which were filed today in redacted form. Each of these documents contains sensitive medical information, as set forth in the SDNY ECF Privacy Policy, regarding Mr. Crumpton. While Rule 4Bi of Your Honor’s Individual Practices suggests that Court approval is not required to seal or redact such sensitive medical information, the e-filing system appears to require a letter motion seeking approval to submit a sealed filing. As such, Mr. Crumpton respectfully requests that the Court grant him leave to file the aforementioned papers under seal. is GRANTED. Although the common law right of public access to judicial "is firmly rooted in our nation's history," this right is not absolute and courts balance competing considerations against" the presumption of access. Lugosch v. Sincerely Co. of Onondaga, 435 F.3d 110, 119-20 (3d Cir. 2006) (quotation marks and , omitted); see Nixon v. Warner Commce'ns, Inc., 435 U.S. 589, 599 (1978) ("[T]he . as to access is one best left to the sound discretion of the trial court, a discretion to Anna Ag uilar in light of the relevant facts and circumstances of the particular case."). There strong privacy interest in the confidentiality of medical records. See Parker v. Brann, Anna Aguilar 12-cv-09408 (LIL) (SDA), 2022 WL 18402115, at *8 (S.D.N.Y. Dec. 17, 2022). it is appropriate here that unredacted versions of the memorandum at law and exhibits be filed under seal. of Court is respectfully directed to close the motion at ECF No. 65 and to ntain ECF Nos. 66-70 under seal. SO ORDERED. ONDA A) “4 =6f2P a“

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