Kumaran v. Vision Financial Markets, LLC

S.D. New York

Kumaran v. Vision Financial Markets, LLC

DecidedNovember 21, 2023

Docket1:20-cv-03871

StatusUnknown

This text of Kumaran v. Vision Financial Markets, LLC (Kumaran v. Vision Financial Markets, LLC) 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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Kumaran v. Vision Financial Markets, LLC, (S.D.N.Y. 2023).

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Opinion

Ko DOCUMENT KLEINMAN GINZBERG LLP ELECTRONICALLY FILED □□□□□□□□□□□□□□□□□□□□□□□□□□□□ ]] DOC #_ ONE OLD COUNTRY ROAD, SUITE 320 DATE FILED:__ 11/21/2023 _ CARLE PLACE, NEW YORK 11514 TEL: (516) 951-0955 WWW.IKLEINMANGINZBERG.COM

November 20, 2023 VIA CM/ECF & EMAIL Application DENIED WITHOUT PREJUDICE. Motior The Honorable Stewart D. Aaron seal must comply with the procedures outlined in United States Mavistrate Judee Sections II(B)(3)/III(E) (Redactions and Filing Unde . . gist Through ECF) of Judge Aaron's Individual Practice. Daniel Patrick Moynihan United States Courthouse 8 500 Pearl Street, Room 11 C SO ORDERED. □□ New York, New York 10007-1312 Dated: November 21, 2023 Aor 4 Re: Kumaran et al. v. National Futures Association, Case No. 1:20-cv-03873 Kumaran et al. vy. ADM Investor Services et al., Case No. 1:20-cv-03668 Kumaran et al. v. Vision Financial Markets et al., Case No. 1:20-cv-03871 Dear Judge Aaron: I am a Partner at Kleinman Ginzberg LLP (“KG LLP”), which represents Plaintiffs Nefertiti Risk Capital Management, LLC (“NRCM”), Nefertiti Asset Management, LLC (“NAM”), and Nefertiti Holding Corporation (“NHC”) (collectively, the “Nefertiti Entities” or “Corporate Plaintiffs”) in each of the above-referenced related matters (the “Cases”). I submit this letter-motion to seal in connection with KG LLP’s motion pursuant to Local Civil Rule 1.4 for leave to withdraw as counsel for the Nefertiti Entities. To preserve the confidentiality of the attorney-client relationship, I respectfully request that the Court permit all additional responses and exhibits related to KG LLP’s respective motions for leave to withdraw including, but not limited to, documents related to Ms. Kumaran’s November 17, 2023 filing in Case No. 1:20-cv-03873 [Docket No. 239], to be filed under seal for in camera review and consideration, i.e., with complete copies of the motion provided to the Nefertiti Entities but not any of the other parties. Team Obsolete Ltd. v. A.H.R.M.A. Ltd., 464 F.Supp.2d 164, 165 (E.D.N.Y. 2006) (granting motion to withdraw upon in camera review holding “documents in support of motions to withdraw as counsel are routinely filed under seal where necessary to preserve the confidentiality of the attorney-client relationship between a party and its counsel, and ... this method is viewed favorably by the courts”).

Respectfully submitted, /s/ Randy E. Kleinman

RANDY E. KLEINMAN For the Firm

Cc: All counsel (via ECF) Nefertiti Entities (via Email at samantha@timetricsrisk.com)

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Ko DOCUMENT KLEINMAN GINZBERG LLP ELECTRONICALLY FILED □□□□□□□□□□□□□□□□□□□□□□□□□□□□ ]] DOC #_ ONE OLD COUNTRY ROAD, SUITE 320 DATE FILED:__ 11/21/2023 _ CARLE PLACE, NEW YORK 11514 TEL: (516) 951-0955 WWW.IKLEINMANGINZBERG.COM

November 20, 2023 VIA CM/ECF & EMAIL Application DENIED WITHOUT PREJUDICE. Motior The Honorable Stewart D. Aaron seal must comply with the procedures outlined in United States Mavistrate Judee Sections II(B)(3)/III(E) (Redactions and Filing Unde . . gist Through ECF) of Judge Aaron's Individual Practice. Daniel Patrick Moynihan United States Courthouse 8 500 Pearl Street, Room 11 C SO ORDERED. □□ New York, New York 10007-1312 Dated: November 21, 2023 Aor 4 Re: Kumaran et al. v. National Futures Association, Case No. 1:20-cv-03873 Kumaran et al. vy. ADM Investor Services et al., Case No. 1:20-cv-03668 Kumaran et al. v. Vision Financial Markets et al., Case No. 1:20-cv-03871 Dear Judge Aaron: I am a Partner at Kleinman Ginzberg LLP (“KG LLP”), which represents Plaintiffs Nefertiti Risk Capital Management, LLC (“NRCM”), Nefertiti Asset Management, LLC (“NAM”), and Nefertiti Holding Corporation (“NHC”) (collectively, the “Nefertiti Entities” or “Corporate Plaintiffs”) in each of the above-referenced related matters (the “Cases”). I submit this letter-motion to seal in connection with KG LLP’s motion pursuant to Local Civil Rule 1.4 for leave to withdraw as counsel for the Nefertiti Entities. To preserve the confidentiality of the attorney-client relationship, I respectfully request that the Court permit all additional responses and exhibits related to KG LLP’s respective motions for leave to withdraw including, but not limited to, documents related to Ms. Kumaran’s November 17, 2023 filing in Case No. 1:20-cv-03873 [Docket No. 239], to be filed under seal for in camera review and consideration, i.e., with complete copies of the motion provided to the Nefertiti Entities but not any of the other parties. Team Obsolete Ltd. v. A.H.R.M.A. Ltd., 464 F.Supp.2d 164, 165 (E.D.N.Y. 2006) (granting motion to withdraw upon in camera review holding “documents in support of motions to withdraw as counsel are routinely filed under seal where necessary to preserve the confidentiality of the attorney-client relationship between a party and its counsel, and ... this method is viewed favorably by the courts”).

Respectfully submitted, /s/ Randy E. Kleinman

RANDY E. KLEINMAN For the Firm

Cc: All counsel (via ECF) Nefertiti Entities (via Email at samantha@timetricsrisk.com)

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Kumaran v. Vision Financial Markets, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kumaran-v-vision-financial-markets-llc-nysd-2023.

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