Huon v. Breaking Media et al

Filing 114

RESPONSE by Gawker Media to MOTION by Plaintiff Meanith Huon to strike reply to response to motion 109 EXHIBIT A OF GAWKER'S REPLY BRIEF FOR DISCLOSING MR. HUON'S SOCIAL SECURITY NUMBER, DATE OF BIRTH, DRIVER'S LICENSE NUMBERMOTION by Plaintiff Meanith Huon to strike reply to response to motion 109 EXHIBIT A OF GAWKER'S REPLY BRIEF FOR DISCLOSING MR. HUON'S SOCIAL SECURITY NUMBER, DATE OF BIRTH, DRIVER'S LICENSE NUMBERMOTION by Plaintiff Meanith Huon for sanctions 110 (Attachments: # 1 Exhibit A-Letter to Plaintiff, # 2 Exhibit B-Follow Up Letter to PLaintiff, # 3 Exhibit C--Additionally Redacted Exhibit)(Feige, David)

GISKAN SOLOTAROFF ANDERSON & STEWART LLP
11 Broadway, Suite 2150
New York, NY 10004
T: 212.847-8315 F: 646.520.3235
December 29, 2011
VIA E-MAIL
Meanith Huon Huon Law Firm
PO Box 441
Chicago, Illinois 60690
312-405-2789
[e-mail]
Re: Meanith Huon v. Gawker Media et al.
Mr. Huon,
Pursuant to your letter, I have just reviewed the attachment and noted that in the corner of
page 5 (of 9) there is information that arguably should have been redacted.1 As I
understand your sensitivity to this issue, and certainly have no interest in publicizing your
personal information I will endeavor to redact that information now, and will promptly
refile the additionally redacted copy.2 As there is no dispute that this exhibit pertains to
you, if there is any additional personal information you would like us to redact, please let
me know promptly and I will be glad to do so. It goes without saying that we will
consent to the motion to strike the exhibit and will re-file the redacted version promptly.
Best,
David Feige
/s/ David Feige

cc: All Counsel of Record

1

We’ll leave aside for now the issue of whether as both an agency proceeding and the
official record of a state court proceeding the document would fall under the exceptions
of Rule 5.2 (b)(3) or (4).
2
While as I understand the rule there is no bar on driver’s license information, in an
abundance of caution and in light of your preferences we will redact that as well.