Martinenko v. 212 Steakhouse Inc.

Opinion

In order to preserve confidentiality of the attorney-client . + relationship, the request to file the declaration of C O B U ry “Pra F a7 □□ J rena under seal ant a G t Cc e { i B OU mM CT granted. e Clerk of Court 1s respectfully directed to FS A TPN CT maintain Dkt. 178 under seal with the current viewing & I oS C 1 S I C | □□□ restrictions. SO ORDERED. Dated: February 3, 2025 C : LB. @cobumerecenbaum.com Direct: 202.744.5003 New York, New York NNIFER L. ROCHON United States District Judge January 31, 2025

VIA ECF The Honorable Jennifer L. Rochon United States Courthouse 500 Pear] Street New York, NY. 10007-1312 Re: = Martinenko, et. al. v. 212 Steakhouse and Nikolay Volper 22-cv-518 (ILR) (RWL) Dear Judge Rochon: We currently represent Defendants 212 Steakhouse, Inc. and Nikolay Volper in the above-referenced action. We request leave to file, under seal and in camera, the Declaration of Counsel (Jonathan W. Greenbaum) in further support of our Motion for Leave to Withdraw as Counsel for Defendants, and that the Court excuse our firm from service of the Declaration on other parties to this litigation or their counsel. Documents in support of motions to withdraw as counsel ate routinely filed under seal when necessary to preserve confidentiality of the attorney-client relationship between a party and its counsel. Thekkek v. Laserscuip, Ine. 2012 WL 225924 at *3 (S.D.N.Y. Jan. 23, 2012). It is also appropriate for a Court considering a counsel’s motion to withdraw to consider in camera submissions in order to prevent a party from being prejudiced by the application of counsel to withdraw. Ashmore v. CGT Grp., Inc. No. 11 Cov, 9611 (AT) Dk. No. 56 (S.D.N.Y. Sep’t 20, 2013 (ordering that counsel need not serve his adversary with such papers); L.R. Civ. 1.4 committee notes (“This is not meant to preclude the Court from permitting the reasons for withdrawal to be stated in camera and under seal in an appropriate case). Should the Court deem it necessary to request additional information from us we would provide it. Respectfully submitted,

3710 Rhacle Island Avenne, NW. 2nd Floor. □□□□□□□□□□ OC 2 307, 6.40.9849 . Gs ROG-4GL 9712 - coburncircepbsuer cont

Jonathan W. Greenbaum IWG:pb ce: Caunsel of Record (ecf)

ITLO Rhoee Island Aver SAU 2nd Plooe. □□□□□□□□□□ □□□ OF BV rary wee bike eK RP CTE TT ah eta □□□□□□□□ □□□ □□□□□□ □□□□□□