Mikhlyn et al v. Bove et al

Filing 201

Letter MOTION for Leave to Electronically File Document under Seal by Boris Kogan. (Attachments: # 1 Declaration Affirmation of Boris Kogan in Opposition to Defendants' Motion for Reconsideration, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14) (Kogan, Boris)

BORIS KOGAN & ASSOCIATES
ATTORNEYS AND COUNSELORS AT LAW
277 BROADWAY, SUITE 701
NEW YORK, NY 10007
TEL: [phone]
FAX: [phone]

April 8, 2011
Sent Via ECF To:
Magistrate Judge Ramon E. Reyes
United States District Court
Eastern District of New York
225 Cadman Plaza East
Brooklyn, NY 11201
Re:

Mikhlyn, et al. v. Bove, et al.
Case No. 1:08-cv-3367

Honorable Judge Reyes:
This firm was prior counsel to the Defendants in the above
referenced action. I submit this letter to request leave to file
the Affirmation in Opposition to Defendants’ motion for
reconsideration along with the exhibits attached thereto under seal
since they contain information protected by the attorney-client
privilege. Although the Court had ruled that Defendants had waived
attorney-client privilege as to discovery matters, these exhibits
contain some communications relating to other issues.
The Eastern District has routinely allowed documents to be
filed under seal “where necessary to preserve the confidentiality
of the attorney-client relationship between a party and its
counsel, and that this method is viewed favorably by the courts.”
Team Obsolete Ltd. v. A.H.R.M.A. Ltd., 464 F.Supp. 2d 164, 165
(E.D.N.Y. 2006) (permitting outgoing counsel to file papers in
support of its motion to be relieved under seal); See also Harrison
Conference Servs., Inc., 806 F.Supp 23 (E.D.N.Y. 1992).
Therefore, I respectfully request that I be granted leave to
file the Affirmation in Opposition to Defendants’ motion for
reconsideration along with the exhibits attached thereto under
seal.
Thank you in advance for your kind consideration.
Very truly yours,
/S/ Boris Kogan
Boris Kogan (BK-9135)
BK:mg