ABC v. DEF

Filing 343

ORDER granting 339 Letter Motion to Seal. Application Granted. The Clerk of Court is respectfully directed to terminate the motion at ECF No. 339. (Signed by Magistrate Judge Valerie Figueredo on 9/15/2023) (vfr)

U.S. Department of Justice

[Type text]

United States Attorney
Southern District of New York
86 Chambers Street
New York, New York 10007

September 14, 2023
By ECF
The Hon. Valerie Figueredo
United States Magistrate Judge
Southern District of New York
500 Pearl Street
New York, NY 10007
Re:

United States ex rel. Bassan et al. v. Omnicare, Inc. & CVS Health Corp.,
15 Civ. 4179 (CM) (VF)

Dear Judge Figueredo:
We write respectfully on behalf of the United States of America (the “Government”) to
request the Court’s leave to file several exhibits to the Government’s letter filed today under a
temporary 14-day seal, pursuant to Rule I.g of Your Honor’s Individual Practices and the
Protective Order entered by the Court on November 29, 2021. See Dkt. No. 102 (the “Protective
Order”).
In producing materials in discovery, Defendants designated certain documents as subject
to the Protective Order. The Protective Order provides a process for the filing of such materials.
Protective Order ¶ 19. Pursuant to that process, the Government respectfully requests that the
Court grant leave to file Exhibits B, D, E, H, I, J, K, L, and M to the Government’s letter under
seal for a period of 14 days. See id. Per the Protective Order, Defendants, as the Producing
Parties, may file a motion to seal the relevant information. See id.
We thank the Court for its consideration of this submission.
Respectfully submitted,
DAMIAN WILLIAMS
United States Attorney
By:
September 15, 2023
The Clerk of Court is respectfully directed to terminate
the motion at ECF No. 339.

cc: All counsel by ECF

/s/ Jennifer Jude
MÓNICA P. FOLCH
JENNIFER JUDE
SAMUEL DOLINGER
LUCAS ISSACHAROFF
JEREMY LISS
Assistant United States Attorneys
[phone]