Regel v. Campbell Soup Company, et al.

• Court: District Court, S.D. New York
• Decided: October 10, 2025
• Docket: 7:24-cv-06541
• Status: Unknown

Opinion

Morgan Lewis

Eric M. Makinen Associate +1,312.324.1470 eric. makinen@morganlewis.com October 9, 2025 VIA ECF Hon. Kenneth M. Karas, U.S.D.J. United States District Court for the Southern District of New York 300 Quarropas Street White Plains, NY 10601 Re: Regel v. Campbell Soup Company, et al., Case No. 7:24-cv-06541-KMK (S.D.N.Y) Your Honor: We represent Defendants in the above-referenced matter. We write pursuant to Your Honor’s Individual Rules of Practice and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions to respectfully request that certain exhibits appended to the Declaration of Eric M. Makinen in support of Defendants’ Summary Judgment Motion be filed under seal, with viewing access granted only to Selected Parties. Plaintiff consents to this request. Defendants have designated Exhibit K, and Plaintiff has designated Exhibit P to the Makinen Declaration as “Confidential” pursuant to the parties’ agreed-upon confidentiality stipulation in this matter. The parties conferred regarding filing of these documents, and it is the Parties’ position that they need to be filed under seal due to the confidential nature of their content. Therefore, Defendants file these documents under seal pursuant to the parties’ confidentiality stipulation, and in accordance with Your Honor’s Individual Rules of Practice and Section 6 of the S.D.N.Y. Electronic Case Filing Rules and Instructions. More specifically, Exhibit K includes details of private transactions between non-parties, including the names of specific business entities involved in these transactions. This document is appended to Defendants’ motion for summary judgment for reasons wholly unrelated to these non-parties’ identities, such as to demonstrate that Plaintiff was appropriately classified as an independent contractor. But because this document happens to identify non-parties (and the details of their private transactions), Defendants request to seal this exhibit. See, e.g., Alexander Interactive, Inc. v. Adorama, Inc., 2014 WL 4346174 at *2 (S.D.N.Y. Sept. 2, 2014) (allowing documents containing confidential information concerning the business relationship between defendant and a non-party entity to be filed under seal); see also Refco Grp. Ltd., LLC v. Cantor Fitzgerald, L.P., 2015 WL 4298572, at *2 (S.D.N.Y. July 15, 2015). Exhibit P contains information relating to Plaintiff's income tax filings. Plaintiff has supplied the following authority in support of his request to seal this exhibit: Yador v. Mowatt, No. 19-CV-4128 (EK)(RML), 2025 WL 1707616, at *3 (E.D.N.Y. June 18, 2025) (quoting Vanguard Dealer Servs., LLC

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Hon. Kenneth M. Karas, U.S.D.J.. October 9, 2025 Page 2 v. Bottom Line Driven, LLC, No. 21-CV-659, 2023 WL 4746180, at *1 (D. Conn. Apr. 27, 2023)) (Sealing is warranted to protect personal ... income tax information.”); Solomon v. Siemens Indus., Inc., 8 F. Supp. 3d 261, 285 (E.D.N.Y. 2014) (‘Tax returns are generally afforded special protection from public disclosure.”). Defendants take no position on these authorities, which were supplied by Plaintiff's counsel; Defendants do not oppose Plaintiff’s request to seal Exhibit P. We thank the Court in advance for its consideration of this request. Respectfully submitted, Granted. [sf Eric M. Makinen Eric M. Makinen So Ordered. Counsel for Defendants VE rn} g cc: Counsel of Record (via ECF) 10/10/25