Nypl v. JP Morgan Chase & Co. et al

Filing 593

ORDER with respect to 577 Letter Motion to Seal. By July 17, 2020, Plaintiffs shall file the "appendix that identifies all parties and attorneys of record who should have access to the sealed documents," pursuant to this Court's Individual Rule I.D.3. So Ordered. (Signed by Judge Lorna G. Schofield on 7/15/2020) (jca)

Case 1:15-cv-09300-LGS Document 593 Filed 07/15/20 Page 1 of 2

ALIOTO LAW FIRM
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ONE SANSOME STREET
35TH FLOOR
SAN FRANCISCO, CALIFORNIA 94104
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TELEPHONE [phone]
FACSIMILE [phone]
By July 17, 2020, Plaintiffs shall file the "appendix that identifies all parties and attorneys of record who should have
access to the sealed documents," pursuant to this Court's Individual Rule I.D.3.
So Ordered.
Dated: July 15, 2020
New York, New York
Re:

Nypl, et al. v. JPMorgan Chase & Co, et al.,
Case No. 1:15-cv-9300

Dear Judge Schofield:
The Nypl Plaintiffs respectfully request approval to file the Joint Letter ordered by
the Court to be filed by the parties on or before July 10, 2020. (Dkt. Nos. 571, 576) under
seal and in redacted form, pursuant to Rule I.D.3 of Your Honor’s Individual Rules and
Procedures for Civil Cases (“Individual Rules”).
The Joint Letter contains references to information designated by Defendants as
confidential/highly confidential pursuant to the Stipulation and Order of Confidentiality
entered by the Court on November 13, 2017 (Dkt. No. 249). In accordance with this
Court’s Individual Rules, Plaintiffs have provisionally redacted references to material
designated as confidential/highly confidential by Defendants. Pursuant to Rule I.D.3 of
this Court’s Individual Rules, however, the party “with an interest in confidential treatment
bears the burden of persuasion.” Individual Rules, Rule I.D.3. In this case, Defendants, as
the parties that made the relevant confidentiality designations, are those with an interest in
confidential treatment. Accordingly, Defendants should “promptly file a letter on ECF
within two business days in support of the motion,” explaining why they seek to have the
joint letter filed in redacted form pursuant to Rule I.D.3 of this Court’s Individual Rules.
Plaintiffs further respectfully reserve the right to challenge the Defendants’
confidentiality designations in the future pursuant to Stipulation and Order of
Confidentiality. Nevertheless, Plaintiffs submit this letter consistent with the applicable
procedures set forth in the Court’s Individual Rules where the filing party is not the party
asserting an interest in the confidential treatment of the redacted information.
In accordance with Your Honor’s Individual Rules and the Confidentiality Order,
the Nypl Plaintiffs respectfully request that this Court grant it permission to file the Joint
Letter under seal and in redacted form.

Case 1:15-cv-09300-LGS Document 593 Filed 07/15/20 Page 2 of 2
Hon. Lorna G. Schofield
July 10, 2020
Page 2 of 2
Respectfully submitted,
ALIOTO LAW FIRM
By: /s/ Joseph M. Alioto
Joseph M. Alioto
Attorneys for Plaintiffs and All Others
Similarly Situated
C: All Counsel by ECF