Vega-Ruiz v. Montefiore Medical Center

Opinion

EISENBERG @ BAUM

USDC SDNY DOCUMENT December 19, 2019 VIA ECF ELECTRONICALLY FILED Magistrate Judge Stewart D. Aaron 500 Pearl Street, Room 1970 DATE FILED:_3/17/2020__ New York, NY 10007 Re: _—_ Lizzette Vega-Ruiz v. Montefiore Medical Center Case No. 1:17-cv-01804-LTS-SDA Dear Judge Aaron, On behalf of Plaintiff, we wish to file documents under seal. In compliance with the Court’s Individual Rules of Practice (Rule III. E.), Plaintiff provided Defendant and the Court with unredacted copies of all documents. Plaintiff also filed a redacted copy of her brief and any documents, “from which the material claimed to require confidential treatment has been removed or concealed.” “[ Notwithstanding the strong presumption of public access to ‘judicial documents’ under the First Amendment and the common law,” (Rule HI. E.) (citing Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-21 (2d Cir. 2006)), the Parties—with a magistrate judge’s approval—entered a protective order. (ECF No. 22.) Exhibits 3 through 6, along with related portions of the brief, fall within this protective order. For these reasons, Plaintiff respectfully requests that the Court allow her to file under seal an unredacted version of her brief and Exhibits 3 through 6, which accompany Plaintiff's Motion for Judgment as a Matter of Law or in the Alternative a New Trial DE#95.

Dated: December 19, 2019 Respectfully submitted, DENIED WITHOUT PREJUDICE. Counsel has not the Court any reason why these exhibits should be LG ot sgl No later than March 24, 2020, counsel shall file a : motion to seal, specifically pointing to the Andrew Rozynski provisions of the protective order and EISENBERG & BAUM, LLP with citations to authority, why these 24 Union Square East, Fourth Floor should be sealed after being entered into the New York, NY 10003 record at trial, especially where documents Tel: (212) 353-8700 as unsealed exhibits during trial are part ofthe Fax: (212) 353-1708 ‘judicial record subject to public inspection." Pelosi v. arozynski@eandblaw.com 607 F. Supp. 2d 366, 377 (E.D.N.Y. 2009) (Bianco, 4orneys for Plaintiff In the alternative, if Plaintiff wishes to withdraw her to seal she shall file unredacted copies of her papers and exhibits no later than March 24, EISENBERG & BAUM, LLP ORDERED. 24 UNION SQUARE EAST FOURTH FLOOR NEW YORK NY 10003 March 17, 2020 PH 212 353 8700 FAX 212 353 1708 A ce □□ EandBLaw.com