Innovatus Capital Partners, LLC v. Neuman et al

Filing 184

ORDER granting 182 Letter Motion for Extension of Time to File. Extension to Monday June 14 at 12 o'clock noon is allowed. So Ordered.. (Signed by Judge Louis L. Stanton on 6/10/2021) (rro)

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~ ase 1:18-cv-04252-LLS Document 182 Filed 06/10/21 Page 1 of 2

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The Honorable Louis L. Stanton
United States District Court
Southern District of New York
Daniel Patrick Moynihan United State Courthouse
500 Pearl Street
New York, NY 10007

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MICHAEL H. MCG INLEY

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Re : Innovatus Capital Partners, LLC v. Neuman, No. 1 :18-cv-04252-LLS (S.D.N.Y.) 1 and
MV Realty PBC, LLC v. Inno vatus Capital Partners, LLC, No. 1 :18-07142-LLS (S.D.N.Y.)

Dear Judge Stanton:

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We are counsel to Innovatus Capital Partners, LLC (" Innovatus"), which is Plaintiff in the first \A"1.v.>
above-captioned action and Defendant and Counter-Claimant in the second. We write to request
a short extension of the Court' s deadline for Innovatus to submit briefing on the question of
whether portions of the MV Realty Parties ' 2 May 24, 2021 Pre-Motion Conference Letter (the
" May 24 Letter") should be filed under seal. See Dkt. 171 (Order setting deadline). In order to
consolidate its briefing on the sealing of confidential information in both of the MV Realty Parties '
recently filed letters, Innovatus respectfully requests that the deadline be moved to Monday, June
14, 2021 , at 5:00 p.m.
Yesterday afternoon, June 9, 2021, the MV Realty Parties filed another letter in support of their
May 24 Letter (the "June 9 Letter"). Dkt. 180. The June 9 Letter added several new references to
information Innovatus has designated as "Highl y Confidential" under the operative Protective
Order. The June 9 Letter also attached as an exhibit a document Innovatus has designated as
" Confidential" and "Highly Confidential." The MV Realty Parties concurrently filed a letter
request to seal the June 9 Letter, in which they noted their request for sealing was "pending a
submission by Innovatus providing a basis for its belief that these materials should be sealed."
Dkt. 179 at 2 .

1

All citations to "Dkt." herein refer to the docket entries in lnno vatus Capital Partners, LLC v. Neuman ,
No. l :18-cv-04252-LLS (S.D.N.Y.).
2

The "MV Realty Parties" refers collectively to Defendants and Counter-Claimants Jonathan Neuman,
Antony Miller, Ritz Advisors, LLC, Greg Williams, Daryl Clark, and Amanda Zachman in the first abovecaptioned action, and Plaintiff MV Realty PBC, LLC in the second above-captioned action.

Case 1:18-cv-04252-LLS Document 182 Filed 06/10/21 Page 2 of 2

Dechert

Hon. Louis L. Stanton
June 10, 2021
Page 2

LLP

The new information in the June 9 Letter is highly sensitive as it reveals Innovatus' proprietary
business development strategy with respect to its RTL business. In the interest of efficiency,
Innovatus proposes to brief the basis for sealing the Confidential and Highly Confidential
information in both letters in a single submission. Accordingly, Innovatus requests this short
extension so that it has the time necessary to fully brief the Court on these new materials. In
accordance with Your Honor's Individual Practices, ~ 1.E, Innovatus represents that it has not
previously asked for an extension with respect to this sealing request and that counsel for the MV
Realty Parties confirmed via e-mail this morning that they do not oppose this request.
For these reasons, Innovatus respectfully requests an extension of today's filing deadline to
Monday, June 14, 2021, at 5:00 p.m., so that it can consolidate its briefing to the Court on whether
portions of the May 24 Letter and the June 9 Letter should be filed under seal.

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Michael H. McGinley

CC: All counsel of record (via ECF)