KN. & LN. 0/b/0 SN. v. Pearl River Union Free School District

BAR [Application Sone The administrative record shall be filed under seal. It appears, however, that Plaintiffs publicly filed the unsealed, unredacted administrative record on this docket (Doc. 11). The Court respectfully directs the Clerk of Court tol, ECF strike that filing (Doc. 11) from the docket but retain the summary docket text for Halpern the record. Plaintiffs may re-file the certified administrative record under seal. . ict Judge ew York koom 530 brk 10601 Philip M. Halpern United States District Judge Dated: White Plains, New York November November 10, 2025 Res KN. & LN. 0/b/0 SN. vy. Pearl River Union Free School District 7:25-cv-05883 Letter-Motion to File Administrative Record Under Seal Dear Judge Halpern: Plaintiffs respectfully request leave to file under seal the Administrative Record from the underlying IDEA due process hearing. The Administrative Record has been Bates stamped with sequential numbering (AR-1 through AR-2314).

This request is based on federal privacy statutes that require protection of student educational records and personally identifiable information. The entire Administrative Record contains education records protected under the Family Educational Rights and Privacy Act (“FERPA”), 20 U.S.C. § 1232g, which prohibits disclosure without parental consent. These records include IEPs, psychological and educational evaluations, progress reports, medical diagnoses, and detailed descriptions of the student’s disabilities and educational needs.

Additionally, the Record contains personally identifiable information about a minor student with disabilities that must be protected under IDEA regulations, 34 C.F.R. § 300.622, and Fed. R. Civ. P. 5.2.

Sealing the entire Record is narrowly tailored to serve these privacy interests, as protected student information appears throughout the document and meaningful redaction would render it incomprehensible for judicial review. This approach satisfies the standard set forth in Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006), as protecting the educational and medical privacy of minor students with disabilities constitutes a “higher value” justifying sealing.

Courts in this Circuit routinely seal administrative records in IDEA cases for these reasons.

Counsel for the parties conferred and agree that sealing is required to comply with FERPA and IDEA confidentiality requirements.

Plaintiffs will electronically file the complete Bates-stamped Administrative Record under seal via ECF.

Respectfully submitted, BARGER & GAINES Paul N. Barger ee New Jersey New York Connecticut Michigan Cedar Ave. 1 Bridge St. 101 Merritt 7 Corp. Park 2723 South State St. Suite 204 Suite 15 Suite 300 Suite 105 Fair Haven, NJ 07704 Irvington, NY 10533 Norwalk, CT 06851 Ann Arbor, MI 48104 Rm. SMNO\ NAN PD. (O1A\ ONI_<O18 De (NN2Z)\ LPRIA_AINN De (OAR\ ALOQO_AODIN