Morrissey v. A&E Television Networks, LLC

Li Davis Wright 1251 Avenue ofthe Americas ij Trem aine Lip New York, NY 10020-1104 Abigail B. Everdell 603 6468 tel 379-5244 fax [email protected] November 15, 2024 VIA FAX & ECF Hon. Ronnie Abrams.

United States District Court Southern District of New York Foley Square, Room 2203 New York, NY 10007 Re: Morrissey v. A&E Television Networks, LLC, et al., No. 1:24-cv-07856 Dear Judge Abrams: We are counsel to Defendant-Counterclaimants A&E Television Networks, LLC, Lifetime Entertainment Services, LLC, Entertainment One Reality Productions, LLC, Creature Films, Inc, and Mark Ford (together, “Defendants”). We write pursuant to Rule 511) of Your Honor’s Individual Rules and Practices in Civil Cases to request leave to file redacted versions of the following documents on the public docket, with the original documents to remain under seal: e A&E Television Networks, LLC and Lifetime Entertainment Services, LLC’s Verified Answer and Affirmative Defenses to Plaintiff's Amended Complaint and Counterclaim e Entertainment One Reality Productions, LLC’s Verified Answer and Affirmative Defenses to Plaintiff's Amended Complaint and Counterclaim e Creature Films, Inc, and Mark Ford’s Verified Answer and Affirmative Defenses to Plaintiff's Amended Complaint and Counterclaim Defendants make this request because these pleadings include references to documents and allegations in Plaintiff's Verified Amended Complaint and exhibits thereto which have been filed under seal, pending a determination by this Court that they should remain under seal. At Plaintiff’ s request, Defendants have redacted these references.

Defendants do not, however, take any position as to whether the material should remain under seal. Plaintiff is aware of her obligation under Rule 5G) of Your Honor’s Individual Rules and Practices in Civil Cases to file a letter within three days explaining the need for these redactions. Defendants defer to Your Honor’s determination of whether Plaintiff meets her burden of demonstrating that the redactions are “necessary to preserve higher values and...

DWT.COM Hon. Ronnie Abrams November 14, 2024 Page 2 narrowly tailored to achieve that aim.” Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 124 (2d Cir. 2006).

We thank the Court for its attention to this matter.

Respectfully submitted, /s/ Abigail B. Everdell Abigail B. Everdell Application granted. Pending resolution of the motion to seal, the aforementioned documents will be temporarily sealed. No later than November 19, 2024, Plaintiff shall file a letter justifying the need to seal each of these documents so the Court may "conduct an individualized review," Brown v. Maxwell, 929 F.3d 41, 51 (2d Cir. 2019), and make "specific, on-the-record findings" as to whether, and the extent to which, sealing is appropriate, Lugosch, 435 F.3d at 126. Plaintiff may, at its discretion, file a single letter in support of sealing the aforementioned documents as well as the documents identified in Defendants' prior letter motion, ECF No. 24.

SO ORDERED. yf / Hon. Ronnie Abrams November 18, 2024