Sango v. City of New York

PALILLOLAW BROADWAY CHAMBERS BUILDING MICHAEL B. PALILLO P.C.

277 BROADWAY SUITE 501 P 212.608.8959 NEW YORK NEW YORK 10007 F 212.608-0304 June 25, 2024 MICHAEL B. PALILLO ESQ. [email protected] Pedro Duran Esq. [email protected] Office Manager Paralegal/Calendar Marianne A. Palillo [email protected] [email protected] Paralegal Bibiana Kmecova [email protected] BY ECF Honorable Ronnie Abrams United States District Judge Southern District of New York Foley Square Room 2203 New York, N.Y. 10007 RE: Sango v. City of New York, et al.

Case No.: 1:24-cv-00142-RA Your Honor: In furtherance of my letter motion to withdraw as Counsel for Sango, dated June 18, 2024, which was granted and So Ordered on June 20, 2024, (Document 14) we write this letter to file, under seal and in camera, the Declaration of Michael B Palillo. (Palillo declaration) We also ask this Court excuse MBP from serving the Palillo Declaration on the other parties to this litigation or their counsel.

The Palillo Declaration sets forth a narrative of communications between Sango and MBP involving certain aspects of the attorney-client relationship that form the basis of MBP’s motion to withdraw. MBP respectfully submits that submission under seal and in camera, for the Court’s eyes only, is appropriate. See, e.g., Thekkek v. LaserSculpt, Inc., No. 11 Civ. 4426 (HB) (JLC), 2012 WL 225924, at *3 (S.D.N.Y. Jan. 23, 2012) (“[D]ocuments in support of motions to withdraw as counsel are routinely filed under seal where necessary to preserve the confidentiality of the attorney-client relationship between a party and its counsel, and ... this method is viewed favorably by the courts.”)

Page 2 June 25, 2024 RE: Sango v. City of New York, et al.

Case No.: 1:24-cv-00142-RA MBP’s request to seal is designed to cover only the Palillo Declaration submitted in support of its motion to withdraw, which contains specifics about communications protected by the attorney-client privilege and work product doctrines.

The grounds for MBP’s motion will be outlined in the Memorandum of Law in Support of MBP’s motion which furnishes the parties with an understanding as to those grounds.

Based on the foregoing, MBP respectfully requests that the Court grant it’s motion to seal.

Respectfully submitted, /s/ Michael B. Palillo, Esq. cc: Via ECF Adam Bevelacqua, ACC Special Federal Litigation Division Consistent with Judge Abrams’ Individual Rule 5(A)(iii)(b), the proposed sealed document shall be filed under seal on ECF. See also Rule 5(A)(ii1)(d). The Court will not rule on any motion to seal without first reviewing the relevant document. SO ORDERED.

Hon. Ronnie Abrams District Judge June 26, 2024