United States of America ex rel. Uri Bassan v. Omnicare, Inc.

Opinion

LAW OFFICES WILLIAMS & CONNOLLY ur: BENJAMIN HAZELWOOD 680 MAINE AVENUE SW EDWARD BENNETT WILLIAMS (1920-1988) (202) 434-5159 PAUL R. CONNOLLY (1922-1978) bhazelwood@we com WASHINGTON, DC 20024 (202) 434-5000 WWW.WC.COM

April 25, 2024 Via ECF The Honorable Valerie Figueredo United States Magistrate Judge for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: — United States ex rel. Bassan v. Omnicare, Inc., No. 15-cv-04179 (CM) (VF) Dear Judge Figueredo: Under Rule I.g of Your Honor’s Individual Practices and the Protective Order in this mat- ter (ECF 102), we write on behalf of Defendants to request the Court seal the exhibits to their let- ter responding to the government’s motion to compel (ECF 449). The exhibits should remain under seal because they contain commercially-sensitive and proprietary information, as defined in 4 of the Protective Order, and for that reason have been designated as “confidential.” Seal- ing is appropriate for that reason, particularly where, as here, any presumption of public access is “not particularly great” because they were submitted in connection with a discovery motion. A/- exander Interactive, Inc. v. Adorama, Inc., 2014 WL 4346174, at 2 (S.D.N.Y. Sept. 2, 2014). The Court previously ordered similar exhibits to discovery motions sealed for these reasons. See, e.g., ECF 457. We appreciate the Court’s consideration.

M E MO \ E N DO RS E D Respectfully submitted, \ A \ \} \ Ni \ LA \ HON. VALERIE’ FIGUEREDO UNITED STATES MAGISTRATE JUDGE Benjamin Hazelwood DATED: April 26, 2024 The motion to seal requested herein is granted. The Clerk of Court is directed to maintain the viewing restrictions on ECF No. 465. The Clerk of Court is respectfully directed to terminate the Motion at ECF No. 464.