Faughn et al v. JPMorgan Chase Bank, NA

Filing 9

MOTION for leave to file (MOTION TO FILE UNDER SEAL DEFENDANT'S MOTION TO CLAW BACK CONFIDENTIAL MATERIALS AND STRIKE THE COMPLAINT) filed by Gardiner B. Davis on behalf of JPMorgan Chase Bank, NA. Suggestions in opposition/response due by 4/10/2014 unless otherwise directed by the court. (Davis, Gardiner)

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF MISSOURI
MARK FAUGHN, TERRIE FAUGHN,
MARVIN L. GLASS, CAROLYN S. GLASS,
THOMAS MCINTYRE, DEBORAH
MCINTYRE and ROGER SPARKS,
Plaintiffs,
v.

Civil Action No. 4:14-cv-00245-BCW

JPMORGAN CHASE BANK, N.A.,
Defendant.
MOTION TO FILE UNDER SEAL DEFENDANT’S MOTION TO
CLAW BACK CONFIDENTIAL MATERIALS AND STRIKE THE COMPLAINT
Defendant JPMorgan Chase Bank, N.A. (“Chase”), by its undersigned counsel, hereby
moves the Court for leave to file certain motion papers in this action under seal.
In anticipation of the hearing scheduled for Tuesday, March 25, 2014 in this matter,
Chase intends to move to claw back certain privileged documents maintained by Plaintiffs in this
action, and to strike the complaint in light of its reference to such privileged information. Chase
seeks to file such papers under seal because its anticipated motion and supporting documents will
make extensive reference to matters that are the subject of an absolute legal privilege under the
Annunzio-Wylie Anti-Money Laundering provisions of the Bank Secrecy Act, 31 U.S.C.
§ 5318(g) and regulations promulgated thereunder.
For the foregoing reasons, Chase requests leave to file under seal its anticipated Motion
to Claw Back Confidential Materials and Strike the Complaint, and supporting affidavits and
documents.

4842-9457-3849.1

Respectfully submitted,
SPENCER FANE BRITT & BROWNE LLP
By:

/s/Gardiner B. Davis
Gardiner B. Davis, #29127
Leslie A. Greathouse, #48341
J. Loyd Gattis, #59699
1000 Walnut Street, Suite 1400
Kansas City, MO 64106
[phone]
[phone] (facsimile)
[e-mail]
[e-mail]
[e-mail]
- And -

OF COUNSEL:
Beth I.Z. Boland (pro hac vice admission in
process)
Steven J. Quinlan (pro hac vice admission in
process)
FOLEY & LARDNER LLP
111 Huntington Ave., Ste. 2600
Boston, MA 02108
[phone]
[e-mail]
[e-mail]
Rachel M. Blise (pro hac vice admission in process)
FOLEY & LARDNER LLP
777 E. Wisconsin Ave.
Milwaukee, WI 53202
[phone]
[e-mail]
ATTORNEYS FOR DEFENDANT

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4842-9457-3849.1

CERTIFICATE OF SERVICE
I hereby certify that the foregoing document was filed utilizing the CM/ECF system
which generated notice to all counsel of record.

/s/ Gardiner B. Davis
Attorney for Defendant
JPMorgan Chase Bank. N.A.

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4842-9457-3849.1