Innovatus Capital Partners, LLC v. Neuman ( 2020 )

vAlOUNAL M EMO ENDORSED COVINGTON Covington & Burling LLP One CityCenter BEIJING BRUSSELS OUBAl JOHANNESBURG LONDON 850 Tenth Street, NW LOS ANGELES NEW YORK SAN FRANCISCO SEOUL Washington, DC 20001-4956 SHANGHAI SILICON VALLEY WASHINGTON T +1202 6626000 October 9, 2020 The Honorable — Seanton United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street, Courtroom 21-C New York, New York 10007 \ g up Re: Innovatus Capital Partners, LLC, v. Neuman et. al. (1:18-cv-04252) Dear Judge Stanton: pov □ □□□□ I write on behalf of Defendants Jonathan Neuman, Anthony Mitchell, Ritz Advisors LLC, _ i 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 “tl Motion for Summary Judgment, Defendants Statement of Material Facts and Exhibits 12-15, □ woe and 17—19* attached thereto (collectively, the “Motion for Summary Judgment Filing”) yon □□□ containing Protected Material under the Protective Order (No. 18-04253 Dkt. No. 75). t □ Ea Although there is a presumption in favor or public access to judicial documents, □□ 4 ad may seal judicial documents if “closure is essential to preserve the higher values and closure is a narrowly tailored to serve that interest.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, sun] 120 (2d Cir. 2006). Defendants’ Motion for Summary Judgment Filing refers to, quotes, and □□□□□ contains information that has been designated by the Plaintiff, Innovatus Capital Partners, LLC, as “CONFIDENTIAL?” under the Protective Order. Id. at 2. The Protective Order further □□□□ core □□ provides: “Where any Confidential or Highly Confidential Materials, or Information derived □□ therefrom, is included in any motion or other proceeding in this Proceeding, the Parties and □□□□□□□□ 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 December □□ 19, 2019, and the Individual Rules of Practice issued of the Court, or any Standing Procedural aay 5. Order subsequently issued by the Court.” Id. at 11. nr hk □□ Accordingly, Defendants respectfully request the Court’s permission to file its Motion □ □ Summary Judgment Filing under seal. daspp™ USDC SDNY ies { □□□□□□ , |, DOCUMENT Bincedly. □□ | || ELECTRONICALLY FILED eis □□□ | DOK #: s/ Jason C. Raofield | ; 7 Jason C. Raofield | if | DATE FILED: fofy[v |i { es 7 □□□ □□ If the court is not inclined to allow for the exhibits to be filed under seal, we note that Exhibit nde 21 contains names and birthdates, and would thus suggest this material be redacted. ents bo bs Lb