# Iowa Public Employees' Retirement System v. Bank of America Corporation > District Court, S.D. New York · March 1, 2022 URL: https://www.frixlaw.com/law-library/cases/10339082 ## Case - **Court:** District Court, S.D. New York - **Decided:** March 1, 2022 - **Opinion:** 100trialcourt - **Cited by:** 0 later opinions in the Frix Law Library ## Citator (automated) - No negative treatment found by the automated citator. That is not the same as a confirmation that the case is good law; read the citing cases. - Full citator and citing cases: https://www.frixlaw.com/law-library/cases/10339082 ## Opinion text 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 662 5487 rwick@cov.com Via ECF February 28, 2022 The Honorable Katherine Polk Failla United States District Court, Southern District of New York MEMO ENDORSE! 40 Foley Square New York, NY 10007 Re: Jowa Public Employees’ Retirement System v. Bank of America Corp., No. 17-cev-6221-KPF (S.D.N.Y.) Dear Judge Failla: Pursuant to Paragraph 9(B) of Your Honor’s individual rules, JPMorgan respectfully requests permission to file under seal and in redacted form certain exhibits to its opposition to Plaintiffs’ letter-motion for leave to serve certain “spoliation-related” interrogatories (ECF No. 527). JPMorgan proposes to file under seal the parties’ Phone Agreement, which was negotiated among all parties in this action and designated “highly confidential” pursuant to the parties’ stipulated protective order (ECF No. 150), and therefore must be filed under seal in accordance with Section 9 of that order. JPMorgan also proposes to redact the names of certain custodians and deponents in this action in one of its exhibits. 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 rules and this Court’s Electronic Case Filing Rules & Instructions, we are contemporaneously filing sealed versions of these three exhibits, with JPMorgan’s proposed redactions highlighted. Respectfully submitted, Ls/ Robert D. Wick Counsel for the JPMorgan Defendants may file an unredacted version of this submission under seal, viewable only to the parties and the Court. The Clerk of Court is directed to terminate the pending motion at docket entry 530. Dated: March 1, 2022 New York, New York --- Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/10339082. Public record. Not legal advice.