Hollis et al v. JPMorgan Chase Bank, N.A.

Filing 111

MOTION to Seal Memorandum in Support of Privileges Asserted in Defendant's Privilege Log by JPMorgan Chase Bank, N.A..(Quinlan, Stephen)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS
GEOFFREY A. HOLLIS, SHARON R.
HOLLIS, EDMUND J. MANSOR, and
ROBERTA M. MANSOR,
Plaintiffs,
v.

Civil Action No. 1:12-cv-10544-JGD

JPMORGAN CHASE BANK, N.A.,
Defendant.

DEFENDANT’S MOTION TO IMPOUND THE SEALED MEMORANDUM
IN SUPPORT OF PRIVILEGES ASSERTED IN DEFENDANT’S PRIVILEGE LOG
As requested by the Court at a hearing on April 11, 2013, Defendant J.P. Morgan Chase
Bank, N.A. (“Defendant”) anticipates filing on Friday, May 31, 2013 a Sealed Memorandum in
Support of Privileges Asserted in Defendant’s Privilege Log (“Privilege Memorandum”),
affidavit, and appendices thereto.

Defendant’s Privilege Memorandum and accompanying

documents make reference to certain information which is prohibited from disclosure by federal
law, and in particular by 31 U.S.C. § 5318(g).
Pursuant to Local Rule 7.2, Defendant respectfully moves the Court for entry of an order
that Defendant’s Privilege Memorandum and accompanying documents, to be submitted to the
Court under separate cover, be filed under seal.
WHEREFORE, Defendant respectfully requests that this Court enter an Order for
impoundment of the Privilege Memorandum and accompanying documents.

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CONCLUSION
For the foregoing reasons, Defendant respectfully requests that the entry of the order
sought herein.
Respectfully submitted,
JPMORGAN CHASE BANK, N.A.
By its attorneys,

/s/ Beth I.Z. Boland
Beth I.Z. Boland, BBO #553654
S. Elaine McChesney, BBO #329090
Lisa K. Haines, BBO #667802
Jacqueline S. Delbasty, BBO #676284
Stephen J. Quinlan, BBO #679205
BINGHAM MCCUTCHEN LLP
One Federal Street
Boston, MA 02110
Tel: [phone]
Fax: [phone]
Date: May 30, 2013

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CERTIFICATE OF SERVICE
I hereby certify that the above document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
and paper copies will be sent to those indicated as non-registered participants on May 30, 2013.
/s/ Stephen J. Quinlan
Stephen J. Quinlan

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