Cesari S.R.L. v. Peju Province Winery L.P. et al

Filing 487

ORDER granting 485 Letter Motion to Seal. The application to temporarily file these documents under seal is granted. So ordered. (Signed by Judge Naomi Reice Buchwald on 11/6/2023) (mml)

HEALY

LLC

82 Nassau St. #60253
New York, NY 10038
T: 212.810.0377
F: 212.810.7036
www.healylex.com
Valeria Calafiore Healy
[e-mail]
By ECF

November 3, 2023
Hon. Naomi Reice Buchwald
United States District Judge
Southern District of New York
500 Pearl Street
New York, NY 10007-1312
RE:

Cesari S.R.L. v. Peju Province Winery L.P. et al., 17 Civ. 873
Application To Seal Exhibits to Various Declarations in Support of
Plaintiff’s Motion for Costs, Attorney’s Fees and Interest

Dear Judge Buchwald:
I write on behalf of Cesari (“Plaintiff”) to respectfully request that the Court allow
Plaintiff to file the below documents under seal for the following reasons.
First set of documents (from Defendants’ production) – Plaintiff cited in its
Memorandum of Law in Support of its Motion for Costs, Fees and Interest (“Motion”) and
supporting Declaration titled the “Exhibits Declaration” (ECF 479), certain documents that the
Peju Defendants produced in discovery and marked confidential. Specifically, those documents
are:
1.
2.
3.
4.

MS Peju 5760-5761 (Marked as Exhibit 2)
MS Peju 5194 (Marked as Exhibit 3)
MS Peju 3007-3008 (Marked as Exhibit 4) (also at Defs.’ Trial Exhibit DX-26)
MS Peju 1890-1891 (Marked as Exhibit 10)

In light of Peju’s designations, Cesari moves to file these documents under seal.
Second set of documents (from Plaintiff’s confidential and attorney-client privileged
materials) – Plaintiff also cites in her Fees Declaration in support of its Motion materials of a
confidential nature consisting of my Firm’s Engagement Letter with Plaintiff, my Firm’s
standard rates, and numerous billing and time records pertaining to nearly 7 years of litigation in
this action that are confidential to my client. While we performed a privilege review and made
as few redactions as possible, the detailed time records still contain confidential client material.

HEALY

LLC

For the foregoing reasons, Cesari respectfully requests that the foregoing application be
granted.
Respectfully submitted,

Valeria Calafiore Healy
Attorney for Plaintiff Cesari S.R.L.

cc: All counsel of record (by ECF)

The application to temporarily file
these documents under seal is
granted.
So ordered.

Dated:

2

November 6, 2023
New York, New York