Royal Borough of Kensington and Chelsea v. Tara Bafna-Louis

Davis Polk Amelia T.R. Starr Davis Polk & Wardwell LLP +4 212 450 4516 450 Lexington Avenue [email protected] New York, NY 10017 davispolk.com Via Electronic Docket January 24, 2023 Re: Royal Borough of Kensington & Chelsea v. Tara Banfa-Louis, No. 22-cv-8303 (PKC) The Hon. P. Kevin Castel Daniel Patrick Moynihan United States Courthouse : Pearl St. New York, NY 10007 Dear Judge Castel: As directed by the Courf write to respectfully request the sealing of Petitioners Exhibit 18, which contains text messages to and from our client CB-L, a minor child The text messages are of a sensitive nature and sealing is warranted to protect the privacy and welibeing’Of our client. See United States v. Amodeo (‘Amodeo ?”), 44 F.3d 141, 146-47 (2d Cir. 1995) (providing that access to judicial documents may be restricted where a party's interests in preventing disclosure outweigh those of the public in gaining access).

Indeed, “family affairs” are “traditionally considered private rather than public,” which “weigh[s] more heavily against access.” Roberts v. Lederman, No. 04-cv-00033, 2004 WL 2238564, at *7 (E.D.N.Y. Oct. 4, 2004) (quoting United States v. Amodeo (“Amodeo I!”), 71 F.3d 1044, 1051 (2d Cir. 1995)).

Thank you for your consideration of this request.

Ve ly yours, Amelia T.R. Starr Application GRANTED.

Dated: 1/24/2023 P. Kevin Castel United States District Judge