Johnston et al v. Apple, Inc.

Filing 12

ENDORSED LETTER: addressed to Judge Jed S. Rakoff from Thomas M. Crispi dated 6/2/2011 re: Counsel for defendant writes pursuant to the parties' conference (the "call") with Judge Rakoff's Chambers on June 1, 2011, Apple Inc., requests permission to file Exhibit A.1 under seal. ENDORSEMENT: So Ordered. (Signed by Judge Jed S. Rakoff on 6/4/11) (js)

Case 1: 11-cv-03321-JSR Document 10

Filed 06/02/11

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June 2, 2011

BYECF
Hon. Jed S. Rakoff
United States District Judge
500 Pearl Street
New York, New York 10007
Re:

Johnston v. Apple Inc., I: II-cv-03321-JSR

Dear Honorable Jed Rakoff:
We represent defendant, Apple Inc., in the above-captioned matter. Defendant is filing a Motion
for Judgment Pursuant to Federal Rules of Civil Procedure 12(b )(6) and Rule 12(d) (the "Motion"), which
must be filed on or before Thursday, June 2, 2011,
Pursuant to the parties' conference call (the "call") with Judge Rakoff's Chambers on June I,
2011, Apple Inc, requests permission to file Exhibit A.I to the Motion under seaL As affirmed in the call,
Plaintiffs consent to the filing of Exhibit A.I under seal.
Exhibit A.I is Apple Inc.'s Services Agreement with independent contractor, Omniscient
Investigation Corporation, for the provision of security services. Exhibit A.I contains confidential
business information that is unrelated to the claims in this case. The disclosure of this information would
cause undue harm to the businesses involved. On that basis, defendant respectfully requests that the
Court grant this application to seal Exhibit A, I to be filed in support oftheir motion.

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Sincerely,

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William K. Phillips
Phillips & Phillips PLLC
30 Broad St., 35 th Floor
New York, New York 10004
[phone]
Attorneys for Plaintiffs

CHICAGO

Thomas M. Crispi

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