upholding trial court's decision to “safeguard . . . confidential material” by placing documents under seal
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- upholding trial court's decision to “safeguard . . . confidential material” by placing documents under seal
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COVINGTON Robert D. Wick
BEIJING BRUSSELS DUBAI FRANKFURT JOHANNESBURG Covington & Burling LLP
LONDON LOS ANGELES NEW YORK PALO ALTO One CityCenter
SAN FRANCISCO SEOUL SHANGHAI WASHINGTON 850 Tenth Street, NW
Washington, DC 20001-4956
T +1202 6625487
rwick@cov.com
Magistrate Judge Sarah L. Cave October 19, 2021
Daniel Patrick Moynihan Courthouse
500 Pearl Street, Room 1670
New York, NY 10007
RE: Jowa Pub. Emps.’ Ret. Sys. et al. v. Bank of Am. Corp. et al.,
No. 17-cv-6221 (KPF/SLC)
Dear Magistrate Judge Cave:
As counsel to the JPMorgan Defendants in the above-captioned action, I write on behalf
of all Defendants to request permission to redact references to confidential material in
Defendants’ letter-motion requesting leave to file a sur-reply brief in opposition to Plaintiffs’
motion for class certification. The material Defendants propose to redact and file under seal
consists solely of references to expert materials that (1) have already been filed under seal
pursuant to sealing orders issued by Judge Failla and (11) were designated “Highly Confidential”
by Plaintiffs pursuant to the protective order issued by Judge Failla. The Second Circuit has
recognized the appropriateness of sealing confidential information. See, e.g., DiRussa v. Dean
Witter Reynolds Inc., 121 F.3d 818, 826 (2d Cir. 1997) (upholding trial court's decision to
“safeguard . . . confidential material” by placing documents under seal).
Pursuant to Your Honor’s Individual Practices and this Court’s Electronic Case Filing
Rules & Instructions, we are contemporaneously filing a sealed version of Defendants’ letter-
motion requesting leave to submit a sur-reply, with Defendants’ proposed redactions highlighted.
Defendants’ letter-motion to seal (ECF No. 472)
Respectfully submitted,
the Clerk of Court is respectfully directed to /s/ Robert D. Wick
access to ECF No. 473 (the "Letter-Motion") to Court
and the case participants. Robert D. Wick
Defendants shall publicly file their Letter- Counsel for the JPMorgan Defendants
imposing the proposed redactions that appear in writing on behalf of all Defendants
473.
of Court is also respectfully directed to close ECF
10/20/2021 a AA
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AN Wy Af / _
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