Listokin v. Miller Zeiderman LLP

__. Application granted. KAUFMAN DOLOWICH VOLUCK ATTORNEYS AT LAW The Clerk of the Court is respecttully directed to seal Doc. 14, permitting Kristina L Duffy, Esq. access only by the parties and the Email: kduffy@kdvlaw.com Court, but retaining the summary docket text for the record. The Clerk of the Court is further June 21, 2022 respectfully directed to terminate the VIA ECF motion sequence pending at Doc. 13. Hon. Philip M. Halpern United States District Court for the Southern District of New YoS0 ORDZAPD. 300 Quarropas Street, Room 530 White Plains, New York 10601 Philip M. Halpern Re: Yehuda Listokin v. Miller Zeiderman LLP, et al. |United States District Judge Case No. 22-cv-02605-PMH Dated: White Plains, New York Dear Judge Halpern: June 22, 2022 Our firm represents the defendants Miller Zeiderman LLP (“the MZ Firm”) and Lisa Zeiderman (“Ms. Zeiderman’’) (collectively “MZ”’) with respect to the Complaint filed by Plaintiff, Yehuda Listokin (“Mr. Listokin”). In accordance with Rule 5 of Your Honor’s Individual Practices, the Southern District of New York’s Standing Order 19 Misc. 583 , Fed. R. Civ. Proc. 5.2, and the Southern District of New York’s Electronic Case Filing Rules & Instructions sections 6 & 21, please allow this correspondence to serve as MZ’s letter Motion requesting that the Court allow MZ to file its Letter Requesting a Pre-Motion Conference with redactions. MZ’s Pre-Motion Conference Request is being submitted in anticipation of MZ’s filing of a Motion to Dismiss pursuant to Fed. R. Civ. Proc. 12(b)(6).. Mr. Listokin’s Complaint concerns allegations of legal malpractice against MZ in connection with its handling of an underlying matrimonial action between Mr. Listokin and his ex-wife. To comply with New York Domestic Relations Law (DRL) § 235 and to protect the privacy interests of the parties to the underlying matrimonial action (other than Mr. Listokin), MZ requests the Court’s permission to file the Pre-Motion Conference Request with the sensitive/personal portions of the Letter redacted and further requests that the Court maintain the unredacted version Riews SMexele | Bannewlosrmia | thleasr keeceux | Cae Erometecee: | lise Aseria | Eleasids | Chiles of the Pre-Motion Conference Request under seal, permitting only the parties to this action and the Court to view it. On May 5, 2022, the Court previously granted Plaintiff’s counsel’s request to file the Complaint under seal. ECF Doc No. 6. Plaintiff’s counsel sought our consent for his application, which we gave. Somewhat disturbingly, when we requested that Plaintiff’s counsel consent to filing this Pre-Motion Request under seal, he refused. After a series of emails attempting to get Plaintiff’s counsel to reconsider his position on consenting to protect personal information regarding nonparties to this litigation, he still refused to consent and merely offered “[d]o what you think you are obligated to do.” Sincerely, Kaufman, Dolowich & Voluck, LLP _________/s/___________________ Kristina I. Duffy cc: Eric Rothstein, Esq. via ECF 4874-9752-9637, v. 1