Doe v. Sarah Lawrence College

Case 7:19-cv-10028-VB Document7 Filed 12/16/19 Page 1 of1 NEW YORK PENNSYLVANIA NEW JERSEY DELAWARE Joshua M. Agins t. 585 454 0759 f. 585 231 1918 [email protected] December 16, 2019 Ppscine □□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□□ memento i usbC SDNY Via CM/ECF | ROCUMENT ELECPROMIC\.

Hon. Vincent L. Briccetti Do oe United States District Judge SAPIR ee ~ United States Courthouse | DATE BILE [ 2 lo / | Quarropas Street, Raom 630 White Plains, NY 10601 Re: Jane Doe v. Sarah Dawrence College et al. (Case No. 7:19-cv-10028) Dear Judge Briccetti: We represent the defendants in\the above-referenced action. On behalf of defenflants, we have agreed to accept service of procesg of plaintiff's Complaint, and we will be filing ¢ Fed. R. Civ. P. 12(b)(6) motion on or before Friday, December 20, 2019. In conjunction with that motion, the defendants will file exhibits that contain highly sensitive information, includihg the names of plaintiff and other Sarah Lawrenca College students who were involved ift the underlying disciplinary proceedings, as well as other identifying information such as telephohe numbers, email addresses, and dorm room information.\Redacting this information, in our view, would make the documents quite cumbersome for the parNes and the Court to read and utilize.

By Order dated October 31, 2019, the Court\granted plaintiff's request to proceg¢d pseudonymously in this matter. (Dkt. 5). The rationale articulated in thgt Order applies even mofe powerfully to the exhibits that defendants intend to file, given theYact that the exhibits contain identifying information not just of plaintiff, but also of students whd are |not parties to this litigatio ccordingly, defendants respectfully request permission to file heir motion exhibits only uhde/’seal. So that we can present an Order to the Clerk at the ime g, we would ask theNCouifé to So-Order this request below if this course of action is acceptabl@to the Court. I have conferred with plaintiffs counsel, who consents to this request.

APPLICATION GRANTED.

Respectfully, Although the relevant documents are judicial documents Ap ff LM (hay——— subject to a common law and First Amendment “ft i presumption in favor of public access, Lugosch v. Pyramid Joshua M. Agins Co. of Onondaga, 435 F.3d 100, 119 (2d Cir. 2006), the JMA/sb Court finds defendants have shown a sufficient basis to CC: Via CM/ECF- justify filing under seal the exhibits to their anticipated James R. Marsh, Esq. motion to dismiss.

Gina M. Decrescenzo, Esq.

Thomas S. D’Antonio, Esq SO eral Gy 1800 BAUSCH & LOMB P. ref 9