McConkey v. The Churchill School and Center

A pea Anne L. Clark RASKIN 212-403-7332 [email protected] CLARK P.C.

November 23, 2025 BY ECF The Honorable Lewis J. Liman U.S. District Court Judge Southern District of New York Pearl Street New York, NY 10007 Re: | McConkey v. The Churchill School and Center, No. 24-cv-06091-LJL Dear Judge Liman: We represent Plaintiff Dennis McConkey in the above-captioned case. Plaintiff hereby respectfully requests that the Court allow Plaintiff to file a document with limited redactions in accordance with Rule 2(H) of Your Honor’s Individual Practices.

Plaintiff seeks to file this matter with redactions because Defendant has marked the transcripts as confidential. Plaintiff has conferred with Defendant, who has asked Plaintiff to redact the names of individuals who raise discrimination complaints and/or engaged in purported misconduct. In accordance with Your Honor’s Individual Rules, Plaintiff respectfully Requests that the Court not rule on this letter-motion to file under seal for one week so that Defendant may submit a letter addressing the redactions.

Respectfully Submitted, /s Anne L. Clark ALC:bw ce: All Counsel of Record (via ECF) Motion to file with redacted material under seal is granted. The presumption of public access is lesser with respect to materials submitted in connection with a discovery motion, Brown v. Maxwell, 929 F.3d 41, 50 (2d Cir. 2019), and there are countervailing interests in the protection of the privacy of third parties, United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (“The privacy interests of innocent third parties . . . should weigh heavily in a court’s balancing equation.”).

December 1. 2025 SO ORDERED. q ° /, Le ~~ LEWES J. LIMAN United States District Judge #10012936