Newman v. Bayer Corporation

Opinion

BURSOR» FISHER

1330 AVE. OF THE AMERICAS cor ca peeanie 32ND FLOOR an ee Fax: 212.989.9163 et Per eine sole mroberts@bursor.com

October 10, 2024 Via ECF The Honorable Kenneth M. Karas United States District Court for the Southern District of New York Charles L. Brieant Jr. Federal Building and United States Courthouse 300 Quarropas Street, Chambers 533 White Plains, NY 10601

Re: | Newman v. Bayer Corporation, No. 7:22-cv-7087-KMK-AEK Plaintiff’s Motion To Seal Documents Dear Judge Karas, I represent Plaintiff Tanysha Newman (“Plaintiff”) in the above matter. I write pursuant to Rule [X.A of Your Honor’s Individual Rules to request an Order permitting Plaintiff to file under seal the portions of Plaintiff's Reply In Support of Class Certification that relies on or mentions documents that have been previously filed under seal. See ECF Nos. 68, 77. Were any of these portions to be disclosed, Defendants would be competitively harmed. Playtex Prods.,2016 WL 1276450, at *11. Accordingly, for the reasons set forth in Plaintiff's Motion to Seal (ECF No. 68), Plaintiff respectfully request that the Court allow these portions to be filed under seal pursuant to Fed. R. Civ. P. 26(c)(1)(G). Pursuant to Rule [X.A of Your Honor’s Individual Practices, I have (i) publicly filed this motion; (ii) publicly filed the aforementioned memorandum with the proposed redactions; and (iii) filed the aforementioned memorandum under seal with the proposed redactions highlighted. apenas Respectfully submitted,

10/10/24 Max S. Roberts ce: All Counsel of Record (via ECF)