King-Knight v. The City of New York et al

Filing 55

ORDER provisionally granting 50 Letter Motion to Seal. Application provisionally GRANTED. SO ORDERED. (Signed by Judge P. Kevin Castel on 7/3/2024) (vfr)

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Case 1:23-cv-04648-PKC Document 50 Filed 06/28/24 Page 1 of 1 THE CITY OF NEW YORK LAW DEPARTMENT MURIEL GOODE-TRUFANT Acting Corporation Counsel ALAN SCHEINER Senior Counsel ascheine@law.nyc.gov Phone: (212) 356-2344 100 CHURCH STREET NEW YORK , NEW YORK 10007 June 28, 2024 Application provisionally GRANTED. BY ECF SO ORDERED. Honorable P. Kevin Castel Dated: 7/3/2024 United States District Court Southern District of New York 500 Pearl St. New York, NY 10007-1312 Re: King-Knight v. City of New York, et al. 23-cv-04648 (PKC) (RWL) Your Honor: I am a Senior Counsel in the Office of Muriel Goode-Trufant, Acting Corporation Counsel of the City of New York, and the attorney assigned to represent City of New York defendants in the above-captioned matter. [ Defendants write to respectfully request permission to file under seal an unredacted copy of Exhibit M to defendants’ motion to dismiss, filed today, which consists of two DNA-related reports generated by the Office of the Chief Medical Examiner.] Defendants will file a redacted copy of Exhibit M on the public docket. The redacted copy is attached to this application. Plaintiff consents to this request. The reason for this request is as follows. New York State Executive Law § 995(d) provides that DNA information may not be disclosed absent consent by the person that is the subject of the DNA analysis, except in criminal cases, or in civil cases where the subject has put his or her own DNA information in issue. Underscoring the state’s very strong policy interest in protecting the privacy of DNA information, an intentional violation of this statute is punishable as a felony. See New York State Exec. Law § 995(f). Although filing of the unredacted DNA reports would not necessarily violate Section 995(d), in an abundance of caution the City respectfully requests to file an unredacted copy under seal, and file a redacted copy on the public docket in which any specific DNA information is redacted. We thank the Court for its consideration of this matter Respectfully submitted, Alan Scheiner CC: Ugochukwu Uzoh, Esq. (via ECF) Attorney for Plaintiff /s// Alan Scheiner Senior Counsel Special Federal Litigation Division Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 1 of 9 EXHIBIT M Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 2 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 3 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 4 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 5 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 6 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 7 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 8 of 9 Case 1:23-cv-04648-PKC Document 50-1 Filed 06/28/24 Page 9 of 9

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