Julian v. MetLife, Inc. et al

Filing 275

ORDER granting 274 Letter Motion for Extension of Time to File. SO ORDERED. (Signed by Judge Alison J. Nathan on 11/25/2020) (rro)

Case 1:17-cv-00957-AJN-BCM Document 274 Filed 11/25/20 Page 1 of 2
275

11/25/20

Christopher A. Parlo

Partner
+1.212.309.6062
[e-mail]

November 25, 2020
VIA ECF
The Honorable Alison J. Nathan
United States District Court, Southern District of New York
40 Foley Square, Room 2102
New York, NY 10007
Re:

Julian et al. v. Metropolitan Life Insurance Co., No. 17-cv-00957 (AJN)(BCM)

Dear Judge Nathan:
We represent Metropolitan Life Insurance Co. in the above-referenced matter. We write
pursuant to Section 1.D of Your Honor’s Individual Practices to respectfully request a one
week extension of time, until December 2, to provide the Court with a letter explaining the
need to seal or redact certain materials attached to the Declaration of Michael D. Palmer in
Support of Plaintiff’s Motion for Class Certification (“Palmer Declaration”). Dkt. 270.
Plaintiffs consent to this request.
In support of their motion for Class Certification, Plaintiffs submitted 22 exhibits which
had been designed as “Confidential” by Defendant, pursuant to the parties’ Amended
Confidentiality Agreement (Dkt. 122). Pursuant to Section 4.B of Your Honor’s
Individual Practices, Defendants currently have until November 25 to submit a letter
explaining the need to seal or redact the 22 exhibits. However, given the number of
exhibits Plaintiffs have filed under seal, as well as the fact that Thanksgiving falls this
week, Defendant respectfully requests a short extension of time to file the letter with the
Court. Defendant would like to carefully review each exhibit so that it only requests
sealing where necessary. To do so, counsel will need to speak to relevant document
authors and/or custodians, as well as with in-house attorneys and business leaders, some of
whom are already out for the holiday. In addition, we hope to speak with Plaintiffs’
counsel in an effort to streamline any remaining issues or create workarounds.
This is Defendant’s first request for an extension of time to submit a letter explaining the
need to seal or redact materials submitted with Plaintiff’s motion for Class Certification.
SO ORDERED.
Morgan, Lewis & Bockius

11/25/20

101 Park Avenue
New York, NY 10178-0060
United States

LLP

+1.212.309.6000
+1.212.309.6001

Case 1:17-cv-00957-AJN-BCM Document 274 Filed 11/25/20 Page 2 of 2
275
Honorable Alison J. Nathan
November 25, 2020
Page 2
Granting Defendant’s request, and allowing its letter to be filed on December 2, 2020, will
not affect any other dates in this action.
Thank you for your consideration of this request.
Respectfully submitted,
/s/ Christopher A. Parlo
Christopher A. Parlo
cc:

Michael Palmer, Esq.; David Tracey, Esq.; Michael R. DiChiara, Esq. (Attorneys
for Plaintiffs, via ECF)