Pierre v. City Of New York

Opinion

Lora | NEW YORK CALIFORNIA GEORGIA PENNSYLVANIA FARUQI & FARUQI Innessa M. Huot ihuot@farugilaw.com May 12, 2023 VIA ECF The Honorable Valerie Figueredo United States District Court Southern District of New York 500 Pearl Street, Courtroom 17A New York, New York 10007 Re: Pierre v. City of New York, et al., No. 1:20-cv-05116-ALC-VF Dear Judge Figueredo: We represent Plaintiffs in the above-referenced action and write, pursuant to Your Honor’s Individual Practices Rule I(g), to respectfully request leave to file documents under seal. Contemporaneously with the instant request, Plaintiffs submit a memorandum of law in support of their motion for leave to file an Amended Complaint (the “Motion for Leave to Amend”). In support of the Motion for Leave to Amend, Plaintiffs submit Exhibit 2, which Defendant Bloomberg L.P. has designated as “Confidential.” Plaintiffs propose that the “Viewing Level” be court personnel and all attorneys of record in this case. Accordingly, in compliance with the parties’ confidentiality agreement, Plaintiffs respectfully request permission to file under seal Exhibit 2 of their Motion to for Leave to Amend. We thank the Court for its time and attention to this matter. Respectfully submitted, SO ORDERED i 4 sq . CN DL Hil > | | (XO \ Innessa M. Huot VALERIE FIGUBREDO United States Magistrate Judge Dated:3-7-2024 the standard set forth by the Second Circuit in Lugosch v. Pyramid Co. of 435 F.3d 110, 124 (2d Cir. 2006), the request to seal is DENIED prejudice. As explained in the Court's prior order denying a similar "broad citations to a Protective Order do not satisfy Lugosch and are. . . ient to overcome the presumption of access as the mere existence of a order says nothing about whether complete reliance on the order to is reasonable.” ECF No. 330 (citation, internal quotation marks, alterations omitted). Plaintiffs are permitted to submit a renewed letter to seal/redact, articulating specifically why sealing is appropriate under the standard. Any such letter motion should be submitted by March 22, 2024. of Court is directed to maintain ECF No. 301 under seal pending ata reneured matinn The (Clerk af Canrt ic alen reonecthaill: directed tr