Medgraph, Inc. v. Medtronic, Inc.MOTION to Seal, MOTION to Seal DocumentW.D.N.Y.August 1, 2011IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NEW YORK ROCHESTER DIVISION _____________________________________ MEDGRAPH, INC., ) ) Plaintiff, ) ) CASE NO. 6:09-cv-06610-DGL-MWP v. ) ) MEDTRONIC, INC. ) ) Defendant. ) MOTION TO SEAL DOCUMENTS Plaintiff, Medgraph, Inc., hereby moves the Court to permit the filing under seal of the following documents: 1) The second paragraph of section five beginning on page 8 of Plaintiff's Reply to Defendant’s opposition to Plaintiff’s Second Motion to Compel Medtronic To Produce Discovery pursuant to Rule 37 of Fed. R. Civ. P.; and 2) Exhibits A-D to the Reply. As grounds for the motion to seal, Plaintiff states that the above-identified documents includes testimony of Defendant’s 30(b)(6) witness regarding documents that were designated by the Defendant as "Confidential" or "Highly Confidential – Attorney's Eyes Only" and the documents designated by the Defendant as Confidential" or "Highly Confidential – Attorney's Eyes Only" pursuant to a protective order entered in this case. For the foregoing reasons, Plaintiff respectfully requests that an order be entered placing the accompanying documents under seal. Case 6:09-cv-06610-DGL-MWP Document 87 Filed 08/01/11 Page 1 of 3 2 Dated: August 1, 2011 Respectfully submitted, s/Dariush Keyhani Dariush Keyhani Sidney R. Bresnick MEREDITH & KEYHANI, PLLC 330 Madison Avenue 6th Floor New York, New York 10017 Telephone (212) 760-0098 Direct Dial: (646) 536-5692 Facsimile (212) 202-3819 dkeyhani@meredithkeyhani.com sbresnick@meredithkeyhani.com Attorneys for Plaintiff Case 6:09-cv-06610-DGL-MWP Document 87 Filed 08/01/11 Page 2 of 3 3 Case 6:09-cv-06610-DGL-MWP Document 87 Filed 08/01/11 Page 3 of 3
