Opinion
1:19-cv-09910-ER
11-10-2021
Leonid Falberg, as representative of a class of similarly situated persons, and on behalf of The Goldman Sachs 401k Plan, Plaintiff, v. The Goldman Sachs Group, Inc., The Goldman Sachs 401k Plan Retirement Committee, and John Does 1-20, Defendants.
Kai Richter, MN#0296545* Michele R. Fisher, NY#MF4600 Paul J. Lukas, MN#22084X* Brock J Specht, MN#0388343* Ben Bauer, MN#0398853 appearing pro hac vice MKLLC LAW Major Khan, NY#2643625 ATTORNEYS FOR PLAINTIFF
Kai Richter, MN#0296545*
Michele R. Fisher, NY#MF4600
Paul J. Lukas, MN#22084X*
Brock J Specht, MN#0388343*
Ben Bauer, MN#0398853
appearing pro hac vice
MKLLC LAW
Major Khan, NY#2643625
ATTORNEYS FOR PLAINTIFF
PLAINTIFF'S MOTION FOR LEAVE TO FILE CERTAIN DOCUMENTS UNDER SEAL
Edgardo Ramos U.S.D.J.
TO ALL PARTIES AND THEIR COUNSEL OF RECORD:
PLEASE TAKE NOTICE that, pursuant to Section 3(ii) of the Court's Individual Practices, Plaintiff Leonid Falberg (“Plaintiff”) hereby moves this Court for an order allowing him to file the following materials under seal in connection with his Motion to Compel Production of Documents Designated as Privileged.
1. An unredacted Memorandum of Law in Support of Plaintiff's Motion to Compel Production of Documents Designated as Privileged (which references material designated as “Confidential” by Defendants);
2. An unredacted Declaration of Kai Richter in Support of Plaintiffs' Motion to Compel Production of Documents Designated as Privileged (which references material designated as “Confidential” by Defendants);
3. The following exhibits to the Declaration of Kai Richter that contain material designated as confidential by Defendants pursuant to the Protective Order in his action (ECF No. 48): 1-5, 7-15.
Plaintiff intends to publicly file a redacted version of the Memorandum that omits references to material designated as “Confidential” by Defendants.
Plaintiff intends to publicly file a redacted version of the Declaration that omits references to material designated as “Confidential” by Defendants.
Plaintiff takes no position on whether these materials have been properly designated as confidential by Defendants, and it shall be Defendants' obligation to support this motion as the parties who designated the underlying material “Confidential.”
WHEREFORE, subject to Defendants making the necessary showing required by the Court's Standing Order, Plaintiff respectfully requests that this Court enter an order allowing him to file the aforementioned materials under seal in connection with his Motion to Compel Production of Documents Designated as Privileged.