Chandler v. International Business Machines Corp.

Filing 25

ORDER granting 23 Letter Motion to Seal. Application granted. The parties should talk to each more before writing to the Court. The Court does not expect any disputes about redactions at this point. SO ORDERED.. (Signed by Judge John G. Koeltl on 10/14/2021) (ks)

Case 1:21-cv-06319-JGK Document 23 Filed 10/14/21 Page 1 of 2

'-TONES DAY
250 V ESEY STREET • NEW Y ORK, N EW Y ORK 10281 . 1047
TELEPHONE:+ 1 .212 .326.3939 • F ACSIM ILE : + 1.2 12.755.73 06

DIRECT NUM BER : (21 2 ) 326-8338
MWLAM PE @JON E SDAY.COM

October 14, 2021

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The Honorable John G. Koeltl
United States District Court
Southern District of New York
500 Pearl St.
New York, NY 10007

Re:

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Chandler v. International Business Machines Corporation, No. 1:2 l-cv06319-JGK
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On behalf of Defendant International Business Machines Corp. ("IBM"), I write to
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Dear Judge Koeltl:

respond to Plaintiff's October 13, 2021 letter (ECF No. 22). IBM does not dispute that it would
be appropriate for the Court, consistent with Judge Furman's modified ruling, see In re: IBM
Arbitration Agreement Litigation, No . l :21-cv-06296 (JMF), at ECF No. 36, to revert to its
original order (ECF No. 18) granting Plaintiff's application to seal the summary judgment filings
provided that copies of the documents with the allegedly confidential material redacted should be
filed in the public docket. IBM notes, however, that in filing this most recent motion (ECF No.
22), Plaintiff yet again did not meet and confer with IBM before seeking relief from the Court.
As we pointed out previously, Plaintiff likewise failed to meet and confer with IBM on sealing
and redaction in advance of filing his summary judgment motion in the first place. (See
Individual Practices Section VI.)
To ensure appropriate conferral takes place regarding redacting and sealing issues, IBM
requests that the Court order (i) the parties to meet and confer on sealing and redaction of the
summary judgment filings, (ii) that no party may file in the public record any material as to
which there is a dispute about sealing and redaction until the Court resolves such dispute, and
(iii) that in the event of a dispute, the party claiming confidentiality must submit a letter to the
Court to justify its position within 3 business days after a live telephone meet-and-confer call on
these issues.

AMSTERDAM • ATLANTA • BE IJIN G • BOSTON • BR IS BA NE • BR USSELS • CH I CAGO • CLEVE L AND • CO L UM BUS • DAL LAS • DETROtT

DUBAI •

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FR ANKFU RT •

HONG KONG •

HOUSTON

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IRV INE •

LONDON

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L OS ANGELES

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MADRID •

MELB OU RN E

M E X IC O CITY • MIAMI • M IL AN • MINNEAPOLIS • MUNICH • N E W YO RK • PAR 1S • PERTH • P ITTSB U RGH • SAN D I EGO • SAN FRANCISCO

sAo PA U L O

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SAUD I ARA B IA

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SHANGHA I

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SILICON V A LL EY

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S IN GAPORE

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S YDN EY

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TA IPE I

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TOKYO

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WASHINGTON

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Case 1:21-cv-06319-JGK Document 23 Filed 10/14/21 Page 2 of 2

JONE S DAY

Hon. John G. Koeltl
October 14, 2021
Page 2

Respectfully submitted,
Isl Matthew W. Lampe

Matthew W. Lampe
cc:

Shannon Liss-Riordan, Esq.