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

Filing 61

MOTION to Seal 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
FEBRUARY 11, 2013 HEARING TRANSCRIPT
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 the transcript of the February 11, 2013
hearing in the matter (“Transcript”) be impounded. The Transcript contains references to and
discussions about documents submitted by counsel for Geoffrey A. Hollis, Sharon R. Hollis,
Edmund J. Mansor, and Roberta M. Mansor (“Plaintiffs”) that are protected from disclosure by
law.
In support of this motion, Defendant states as follows:
1.

On February 11, 2013, this Court held a hearing regarding Plaintiffs’ submission

of filings on January 16, January 22, February 5 and February 6, 2013.

At the hearing,

Defendant argued that these filings contained information which is prohibited from disclosure by
federal law, and in particular by 31 U.S.C. § 5318(g). Defendant requested, among other things,
that Plaintiffs withdraw the filings containing federally-protected information. Defendant also
requested that the hearing be sealed to maintain this protection.
2.

Defendant contends that the Transcript will contain references to and discussions

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about documents, the existence of which is prohibited by disclosure by federal law, and
accordingly, any references to or discussions about such documents are also confidential.
3.

Although no protective order has been agreed upon by the parties, Defendant

believes that the Transcript should remain under seal until further order of the Court.
WHEREFORE, Defendant respectfully requests that this Court enter an Order for
impoundment of the Transcript.
CONCLUSION
For the foregoing reasons, Defendant respectfully requests that the entry of the order
sought herein.
Respectfully submitted,
J.P. MORGAN 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 19, 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 February 19,
2013.
/s/ Stephen J. Quinlan
Stephen J. Quinlan

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