Arkansas Teacher Retirement System v. Allianz Global Investors U.S. LLC et al

Filing 101

ORDER granting 96 Letter Motion to Seal. Application GRANTED. Exhibits 1, 2, and 4-7 to the Declaration of Michael Blatchley in Opposition to Defendant's Omnibus Motion to Dismiss may be filed under seal, visible only to the Court and the parties. Additionally, Plaintiff may redact references to these exhibits in its memorandum of law.. (Signed by Judge Katherine Polk Failla on 4/27/2021) (nb)

BERNSTEIN LITOWITZ BERGER
& GROSSMANN LLP
1251 Avenue of the Americas
New York, NY 10020

KAPLAN FOX & KILSHEIMER LLP
850 Third Avenue, 14th Floor
New York, NY 10022

April 26, 2021
VIA ECF
The Honorable Katherine Polk Failla
United States District Court
Southern District of New York
40 Foley Square, Room 2103
New York, NY 10007
Re:

MEMO ENDORSED

Arkansas Teacher Retirement System v. Allianz Global Investors U.S. LLC, et al.,
No. 20-cv-5615-KPF

Dear Judge Failla:
Pursuant to Rule 9 of Your Honor’s Individual Practices and Section IX of the Stipulated
Amended Protective Order entered in the Related Actions1 by the Court on April 21, 2021
(“Protective Order”) (ECF No. 90), Plaintiff Arkansas Teacher Retirement System (“Plaintiff”)
requests permission to file the documents attached as Exhibits 1, 2 and 4-7 (“Sealed Exhibits”) to
the Declaration of Michael Blatchley in Opposition to Defendant Allianz Global Investors U.S.
LLC’s Omnibus Motion to Dismiss, under seal in their entirety. Additionally, Plaintiff requests
permission to redact references to the Sealed Exhibits in Plaintiffs’ Joint Response in Opposition
to Defendant Allianz Global Investors U.S. LLC’s Omnibus Motion to Dismiss (“Plaintiffs’
Opposition”). The Sealed Exhibits and redacted portions of Plaintiffs’ Opposition have been
designated as “Confidential” by Defendant Allianz Global Investors U.S. LLC (“Allianz”) under
the Protective Order. In accordance with Rule 9(B) of Your Honor’s Individual Practices, we will
file under seal unredacted copies of the Sealed Exhibits and Plaintiffs’ Opposition as well as a
copy highlighting the information that has been redacted from Plaintiffs’ Opposition.
Plaintiff does not concede that the materials designated as confidential by Allianz are
confidential.
Respectfully,
/s/ Michael Blatchley
James A. Harrod
Michael Blatchley
BERNSTEIN LITOWITZ BERGER
& GROSSMANN LLP

/s/ Frederic S. Fox2
Frederic S. Fox
Donald R. Hall
KAPLAN FOX & KILSHEIMER
LLP

1

The Related Actions are the twelve captioned cases as defined in Civil Management Plan #1 entered by
the Court on December 7, 2020 (ECF No. 65).
2

Counsel’s electronic signature (“/s/”) is signed with consent pursuant to Rule 8.5 of this Court’s
Electronic Case Filing Rules & Instructions as of February 1, 2021.

Application GRANTED.
Exhibits 1, 2, and 4-7 to the Declaration of
Michael Blatchley in Opposition to Defendant’s Omnibus Motion to
Dismiss may be filed under seal, visible only to the Court and the
parties. Additionally, Plaintiff may redact references to these
exhibits in its memorandum of law.
Dated:

April 27, 2021
New York, New York

SO ORDERED.

HON. KATHERINE POLK FAILLA
UNITED STATES DISTRICT JUDGE