Innovatus Capital Partners, LLC v. Neuman et al
ORDER denying 101 Letter Motion to Seal. I have determined each of these items in detail, and find none of them - submitted to affect the determination of a motion for summary judgment presents a "most compelling reason " to seal it from public access. See Lingosch at 123. This application is denied. The birthdates are to be redacted. (Signed by Judge Louis L. Stanton on 10/14/2020) (rro)
Case 1:18-cv-04252-LLS Document 106 Filed 10/14/20 Page 1 of 1
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Covington & Burling LLP
850 Tenth Street, NW
Washington, DC 20001•4956
T + l 202 662 6000
October 9, 2020
TI1e Honorable Louisl\J jtanton
United States District io~rt for the Southern District of New York
Daniel Patiick Moynihan United States Comthouse
500 Pearl Street, Courtroom 21-C
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Re: Innovatus Capital Partners, LLC, v. Neuman et. al. (1:18-cv-04252)
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Dear Judge Stanton:
I write on behalf of Defendants Jonathan Neuman, Anthony Mitchell, Ritz Advisors LLC~ ~ ~t
Greg Williams, Daryl Clark, and Amanda Zachman (together, "Defendants") to respectfully
request permission to file under seal Defendants Memorandum of Law in Support of Defendants
Motion for Summary Judgment, Defendants Statement of Material Facts and Exhibits 12-15,
and 17-19 1 attached thereto (collectively, the "Motion for Summary Judgment Filing") ~ . ,
containing Protected Material under the Protective Order (No. 18-04253 Dkt. No. 75).
Although there is a presumption in favor or public access to judicial documents, a~l:Jurt # ~ ~ .'.J1~ '
may seal judicial documents if "closure is essential to preserve the higher values and closure is
narrowly tailored to serve that interest." Lugosch v. PlJramid Co. of Onondaga, 435 F.3d no,~~_..~ ,h ""
120 (2d Cir. 2006). Defendants' Motion for Summary Judgment Filing refers to, quotes, and
contains information that lias been designated by the Plaintiff, Innovatus Capital Partners, LLC,
as "CONFIDENTIAL" under the Protective Order. Id. at 2. The Protective Order further
provides: "Where any Confidential or Highly Confidential Mate1ials, or Information derived'"~
therefrom, is included in any motion or other proceeding in this Proceeding, the Parties and any~~
involved non-party shall follow the procedures outlined in Fed. R. Civ. P. 5.2, the Standing
Order Regarding Electronic Filing Under Seal in Civil and Miscellaneous Cases dated DecemberJ ~
19, 2019, and the Individual Rules of Practice issued of the Court, or any Standing Procedural
Order subsequently issued by the Court." Id. at 11.
°'-"<,,&, J.. ..,t t 1.1 .
Accordingly, Defendants respectfully request the Court's pem1ission to file its Motion fOf"'d-- l.! ;~
Summary Judgment Filing under seal.
~cttr''",n•"'!I USDC' SD~Y
Ii DOCl \1ENT
·I ~ATE FILED: /o/;'ffV
s/Jason C. Raofield
Jason C. Raofield
If the court is not inclined to allow for the exhibits to be filed under seal, we note that Exhibit
21 contains names and birthdates, and would thus suggest this material be redacted.
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