Genworth Financial Wealth Mgmt Inc v. McMullan et alMOTION to Seal Exhibit 1 to Defendants' Motion for ClarificationD. Conn.January 13, 2012 -1- UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT GENWORTH FINANCIAL WEALTH MANAGEMENT, INC. Plaintiff, vs. TIMOTHY MCMULLAN, JAMES COOK, TIMOTHY MCFADDEN, KAREN BAZON, TAMARA RIVERA AND TJT CAPITAL GROUP, LLC Defendants. ______________________________ TIMOTHY MCMULLAN, JAMES COOK, TIMOTHY MCFADDEN, AND TJT CAPITAL GROUP, LLC Third-Party Plaintiffs, vs. GURINDER AHLUWALIA Third-Party Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Civil Action No. 3:09-CV-01521-PCD JANUARY 13, 2012 DEFENDANTS’ MOTION FOR LEAVE TO FILE UNDER SEAL Pursuant to Federal Rule of Civil Procedure 26(c) and Connecticut Local Rule 5(e), Defendants and Third-Party Plaintiffs Timothy McMullan, James Cook, Timothy McFadden, Karen Bazon, Tamara Rivera, and TJT Capital Group, LLC. (collectively “Defendants”), hereby move for permission to file an exhibit under seal. Case 3:09-cv-01521-PCD Document 254 Filed 01/13/12 Page 1 of 4 -2- The document subject to this Motion is Exhibit 1 to Defendants’ Motion to Clarify Prior Orders. The exhibit consists of an arbitration demand filed with the Financial Industry Regulatory Authority (“FINRA”). Defendants submit that there is good cause to seal the exhibit because documents in FINRA Dispute Resolution Arbitrations are confidential and not subject to public disclosure. Thus, the document, consisting of the arbitration demand, should be filed under seal. WHEREFORE, Defendants respectfully request that their Motion to Seal the referenced exhibit related to Defendants’ Motion to Clarify Prior Orders be granted, and that Exhibit 1 should be placed under seal for court review only. Case 3:09-cv-01521-PCD Document 254 Filed 01/13/12 Page 2 of 4 -3- Respectfully submitted, DEFENDANTS TIMOTHY MCMULLAN, JAMES COOK, TIMOTHY MCFADDEN, KAREN BAZON, TAMARA RIVERA AND TJT CAPITAL GROUP, LLC AND THIRD-PARTY PLAINTIFFS TIMOTHY MCMULLAN, JAMES COOK, TIMOTHY MCFADDEN AND TJT CAPITAL GROUP, LLC By: /s/ Ka Fei Wong David P. Friedman (ct03558) dfriedman@murthalaw.com Ka Fei Wong (ct28130) kwong@murthalaw.com Murtha Cullina, LLP 177 Broad Street Stamford, Connecticut 06901 Phone: 203-653-5400 Fax: 203-653-5444 Case 3:09-cv-01521-PCD Document 254 Filed 01/13/12 Page 3 of 4 3003513v2 -4- CERTIFICATION I hereby certify that on January 13, 2012, a copy of the foregoing was electronically filed. Notice of this filing will be sent by e-mail to all parties by operation of the Court’s electronic filing system or by mail to anyone unable to accept electronic filing as indicated on the Notice of Electronic Filing. Parties may access this filing though the Court’s CM/ECF System. By /s/ Ka Fei Wong Ka Fei Wong (ct28130) Case 3:09-cv-01521-PCD Document 254 Filed 01/13/12 Page 4 of 4