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

Filing 48

MOTION to Seal Document by JPMorgan Chase Bank, N.A.. (Attachments: # 1 Text of Proposed Order)(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 SUPPLEMENTAL MEMORANDUM
In anticipation of the hearing in this matter scheduled for Monday, February 11, 2013,
Defendants anticipate filing a Supplemental Memorandum In Support Of Defendants’ Motions
Seeking Relief In Connection With Plaintiffs’ Filling Of Prohibited Materials (the
“Supplemental Memorandum”). Defendant’s Supplemental Memorandum makes reference to
certain information reflected in documents submitted to this Court by counsel for Plaintiffs on
January 16, January 22, February 5, and February 6, 2013 and 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 J.P. Morgan Chase Bank, N.A. (“Defendant”)
respectfully moves the Court for entry of an order that Defendant’s Supplemental Memorandum,
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 Supplemental Memorandum.

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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
Jacqueline S. Delbasty, BBO #676284
Stephen J. Quinlan, BBO #679205
BINGHAM MCCUTCHEN LLP
One Federal Street
Boston, MA 02110
Tel: [phone]
Fax: [phone]
Date: February 8, 2013

-2A/75384405.1

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 February 8,
2013.
/s/ Stephen J. Quinlan
JStephen J. Quinlan

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