Washington v. NYC Madison Avenue Medical P.C.

Opinion

LAW OFFICE OF

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Yuriy Moshes, Esq. Gennady Litvin, Esq. Jessenia Maldonado, Esq. Members of NJ and NY Bar. Members of NY Bar. November 30, 2023 Via ECF Honorable Laura Taylor Swain Chief United States District Judge United States District Court MEMO ENDORSED Southern District of New York 40 Foley Square New York, New York 10007 Re: Stacy Washington v. NYC Madison Medical, et al. Case No. 1:20-cv-3446 (LTS)(SN) Dear Judge Swain: Moshes Law represents the Plaintiff, Stacy Washington, in the above-referenced matter. The parties, after mediation, have concluded a settlement agreement. The settlement agreement (Document Number 83) was filed with the Court today, but it was mistakenly not sealed, although Plaintiff's counsel thought that he had marked the box for the document to be sealed. Plaintiff’s counsel immediately called the Clerk’s Office and the Clerk’s Office agreed to immediately seal the document, but they instructed that a motion must be filed to maintain the seal of that document. The parties jointly request that the Court maintain the seal on the Settlement Agreement (Document Number 83). The Plaintiffs counsel apologizes to the Court for the need for this motion. Thank you for your kind attention to this matter. parties’ joint application to seal does not conform to Respectfully submitted, A.5 of the Court's Individual Practice Rules, the is denied without prejudice to renewal. The parties’ By: /s/ Gennady Litvin on is directed to subdivision A.5(b)(ii) in particular, which Gennady Litvin, Esq. 4 a motion to file sealed or redacted materials to justify the 517 Brighton Beach Ave., 2° Floor in light of the standards set forth in Lugosch v. Pyramid Brooklyn, New York 11235 435 F.3d 110 (2d Cir. 2006). The Clerk of Tel: 718-504-6090 is respectfully directed to maintain the filed settlement glitvin@ mosheslaw.com (DE 83) under seal for 30 days, or until the Court is rule on the merits of a properly filed motion to seal, the narties renew their request.