City of Providence, Rhode Island v. Bats Global Markets, Inc. et al

Filing 760

ORDER granting 755 Letter Motion to Seal. Once again, the motion is granted temporarily and the Court will assess whether to keep the materials sealed when deciding the underlying motion. The Clerk of Court is directed to terminate ECF No. 755. SO ORDERED.. (Signed by Judge Jesse M. Furman on 10/12/2021) (ks)

Thomas G. Hoffman, Jr.
Partner
212 907 0744 direct
212 907 0700 main
212 883 7544 fax
[e-mail]

October 8, 2021

New York Office
140 Broadway
New York, NY 10005

VIA ECF
Hon. Jesse Furman
United States District Court
Southern District of New York
40 Centre Street, Room 2202
New York, NY 10007
Re:

City of Providence, et al. v. BATS Global Markets, Inc., et al., No. 14-cv-02811: Plaintiffs’ Letter
Motion for Leave to File Under Seal

Dear Judge Furman:
We write pursuant to Section 7(c) of Your Honor’s Individual Rules of Practice to respectfully seek
leave to file under seal and redact certain materials from Plaintiffs’ forthcoming Reply Memorandum
of Law in Further Support of Plaintiffs’ Motion to Exclude the Report of James R. Burns.
Plaintiffs’ memorandum of law was filed in public redacted and sealed unredacted forms (See ECF
Nos. 642, 647), which sealing the court temporarily approved in its order of July 27, 2021 (See ECF
No. 666). Nasdaq similarly filed its memorandum of law in opposition in public redacted and sealed
unredacted forms (See ECF Nos. 725, 735), which sealing the court temporarily approved of in its
order of September 20, 2021 (See ECF No. 743).
The proposed redactions include references to documents designated Confidential or Highly
Confidential by the Nasdaq and NYSE Defendants pursuant to the Stipulated Protective Order
(ECF No. 402). Accordingly, consistent with prior sealing orders, Plaintiffs respectfully request that
the Court temporarily grant leave to file the reply memorandum of law in public redacted and sealed
unredacted forms.
Respectfully submitted,
By: /s/Thomas G. Hoffman, Jr.
LABATON SUCHAROW LLP
140 Broadway
New York, NY 10005
Telephone: [phone]

Once again, the motion is granted temporarily and the Court
will assess whether to keep the materials sealed when
deciding the underlying motion. The Clerk of Court is directed
to terminate ECF No. 755. SO ORDERED.

October 12, 2021