Noriega v. Abbott Laboratories

Opinion

KIRKLAND & ELLIS LLP

1301 Pennsylvania Avenue, N.W. Washington, D.C. 20004 Michael A. Glick, P.C. United States To Call Writer Directly: Facsimile: +1 202 389 5218 +1 202 389 5000 +1 202 389 5200 michael.glick@kirkland.com www. kirkland.com

May 8, 2026 VIA CM/ECF Honorable Paul A. Engelmayer United States District Court Southern District of New York 40 Foley Square New York, New York 10007 Re: Noriega v. Abbott Laboratories, Case No. 23-CV-4014 (PAE) Dear Judge Engelmayer: On May 6, 2026, the Court ordered Abbott Laboratories (“Abbott”) to file the transcript of the deposition of Plaintiff Joanne Noriega on the docket by May 8, 2026. See Dkt. No. 127. Pursuant to the Court’s Individual Rules & Practices in Civil Cases J 4.B, the parties respectfully request permission to provisionally file the transcript under seal pending submission of a more narrowly tailored public version with proposed redactions, if the Court deems appropriate. The parties have conferred regarding this issue. The transcript contains testimony concerming Plaintiff's minor grandson, including medical information and records, as well as other sensitive personal information, including Plaintiff's home address and employment history. See JL. ex rel. J.P. v. New York City Dep’t of Educ., 2024 WL 291218, at *3 (S.D.N.Y. Jan. 25, 2024) (noting that courts “generally permit medical and other sensitive information of minors to remain under seal”). Accordingly, to timely comply with the Court’s Order, the parties respectfully request permission to file the transcript under seal at this time. To the extent the Court deems necessary, the parties will promptly meet and confer regarding a publicly filed redacted version of the transcript containing only those redactions necessary to protect sensitive information. We thank the Court for its consideration. The Court thanks counsel for promptly filing Respectfully, The Court will assess whether the transcript remain under seal when the Court resolves the Michael A. Glick, P.C. joint omnibus motion to seal. See Dkt. 118. Michael A. Glick, P.C. ep PAULA. aun OR TInited States THetrict Thidoe