Capitol Records, LLC v. Redigi Inc.

Filing 67

MOTION to Seal. Document filed by Redigi Inc..(Adelman, Gary)

Gary P. Adelman, Esq.
MEISTER SEELIG & FEIN LLP
Attorneys for Defendant ReDigi Inc.
Two Grand Central Tower
140 East 45th Street, 19th Floor
New York, New York 10017
[phone]
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
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CAPITOL RECORDS, LLC,
Civil Action No: 12 CIV 0095
(RJS)

Plaintiff,
- against REDIGI, INC. ,
Defendant.
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NOTICE OF MOTION
PLEASE TAKE NOTICE, that upon the accompanying Memorandum of Law dated
July 27, 2012, the Declaration of Lawrence S. Rudolph (Rogel), dated July 27, 2012, with
the exhibit annexed thereto and all prior proceedings had herein, Defendant ReDigi Inc.
(“ReDigi”), will move this Court before the Honorable Richard J. Sullivan, United States
District Judge for the Southern District of New York, at the United States Courthouse, 500
Pearl Street, New York, New York 10007, for an order permitting the continued sealing of
the following documents to be conditionally filed under seal by ReDigi and Plaintiff Capitol
Records, LLC (“Capitol”) pursuant to the Court’s July 12, 2012 endorsed letter order:
(1) Deposition Excerpts of Rudolph Rogel Deposition taken on June 18, 2012,
attached to Capitol’s Motion for summary judgment; (2) Deposition Excerpts of Rudolph
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Rogel Deposition taken on June 18, 2012, attached to ReDigi’s Motion for summary
judgment; (3) Deposition Excerpts of Ossenmacher Deposition, taken on June 19, 2012,
attached to Capitol’s Motion for summary judgment; (4) Deposition Excerpts of
Ossenmacher Deposition, taken on June 19, 2012, attached to Redigi’s Motion for summary
judgment; (5) Exhibits “K”, “L” and “M” attached to the Declaration of Richard Mandel in
support of Capitol’s Motion for summary judgment; (6) Capitol’s 56.1 Statement of
Uncontested Facts, attached to Plaintiff’s Motion; (7) ReDigi’s 56.1 Statement Of
Uncontested Facts, attached to ReDigi’s Motion; (8) Capitol’s Memorandum of Law, dated
July 20, 2012, in support of its motion for summary judgment; (9) ReDigi’s Memorandum
of Law, dated July 20, 2012 in support of its motion for summary judgment; (10).
Declaration of Gary Adelman dated July 20, 2012, in support of ReDigi’s Motion for
summary judgment; (11) Declaration of Larry Rudolph (aka Lawrence S. Rogel), dated July
20, 2012, in support of the ReDigi Motion; (12) Declaration of Colin Worth, dated July 20,
2012, in support of the ReDigi Motion for summary judgment; and (13) Declaration of
Jonathan Lin, dated July 20, 2012, in support of the ReDigi Motion for summary judgment,
and such other and further relief as is just and proper.
PLEASE TAKE FURTHER NOTICE, that ReDigi respectfully requests that the
Court hear oral argument as it may assist the Court, on a date and at a time designated by the
Court.

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Dated: New York, New York
July 27, 2012
Respectfully submitted,
MEISTER SEELIG & FEIN LLP

/s/Gary Adelman________________
Gary Adelman, Esq.
Attorneys for ReDigi Inc.
Two Grand Central Tower
140 East 45th Street, 19th Floor
New York, New York 10017
Telephone: [phone]
Fax: [phone]
E-mail: [e-mail]
TO:
Richard S. Mandel, Esq
Jonathan Z. Mandel, Esq.
Cowan, Liebowitz & Latman, P.C.
1133 Avenue of the Americas
New York, New York 10036-6799
[e-mail]
[e-mail]

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