Handberry v. Thompson

Opinion

THE 49 Thomas Street New York, NY 10013 LEGAL AID (212) 577.3300 SOCIETY wn legalardnyc-org CRIM NAL Alan Levine DEFENSE President Twyla Carter Attorney-in-Chief Chief Executive Officer VIA ECF Justine M. Luongo Chief Attorney $O ORDERED: Mary Lynne Werlwas Directo! Hon. Robert W. Lehrburger 04/07/2025 — Prisoners’ Rights Project United States Magistrate Judge ———————— : . : HON. ROBERT W. LEHRBURGER Daniel Patrick Moynihan UNITED STATES MAGISTRATE JUDGE United States Courthouse 500 Pearl St. New York, NY 10007 Re: Handberry v. Thompson, 96-cv-6161 (GBD)(RWL) Dear Judge Lehrburger: We write on behalf of Plaintiffs in the above-referenced matter to request an order under Your Honor’s Individual Rule III.G authorizing the sealed filing of Plaintiffs’ reply to Defendants’ March 31, 2025 Letter, ECF No. 393. Plaintiffs have no confidentiality interest in the information contained within the reply. Defendants, however, have expressed concerns regarding the disclosure of ostensibly “confidential” information in certain of Plaintiffs’ recent filings. See, e.g., Letter from B. Anderson, dated Mar. 20, 2025, ECF No. 391 at 1, 4. Defendants’ concerns have not yet been addressed by the Court or otherwise resolved. Plaintiffs therefore seek to provisionally file the entirety of their reply under seal so that Defendants may have an opportunity to seek continued protection of any material they believe may be confidential. Defendants have agreed to this process. At this time, Plaintiffs take no position as to any such request that Defendants may file. The parties have agreed to work together to submit an unsealed version of Plaintiffs’ reply by April 10, 2025.

Justice in Every Borough.

Page 2 Respectfully submitted, THE LEGAL AID SOCIETY PRISONERS’ RIGHTS PROJECT /s/ Lauren Stephens-Davidowitz Lauren Stephens-Davidowitz Antony Gemmell Mary Lynne Werlwas 49 Thomas Street, 10th Floor New York, New York 10013 (212) 577-3530 PAUL, WEISS, RIFKIND, WHARTON & GARRISON LLP Roberto Finzi Tyler A. Anger 1285 Avenue of the Americas New York, New York 10019 (212) 373-3000 Attorneys for Plaintiffs

Justice in Every Borough.