Case 1:22-cv-10904-JSR Document 355 Filed 03/12/24 Page 1 of 5 LAW OFFICES & CONNOLLYLLP• STEPHEN I.. WOHLGEUUTH (202) 434-5390 swohlgemuth@wcsom 680 MAINE AVENUE SW WASHINGTON, DC 20024 (202) 4345000 WWW.WC.COM EDWARD BENNETT 119201988) PAUL R. CONNOLLY (1922-1978) March 12, 2024 VIA ECF Re: Doe v. JPMorgan Chase Bank. N.A.• No. 1:22-cv-10019 (JSR): USVI v. JPMorgan Chase Bank, N.A., 1:22-cv-10904 (JSR) — Deposition Testimony Sealed Under Protective Order Dear Judge Rakoff: Mr. Staley opposes in part the letter motions filed by nonparty The New York Times Company ("the Times") in the above-captioned matters. This Court has previously recognized the sensitive nature of the allegations in these cases and found "good cause" to issue an "appropriately tailored" protective order that governed the use of confidential information created or exchanged during discovery. See ECF No. 35, 22-cv-10019; ECF No. 15, 22-cv-10904. The Times seeks to unseal five exhibits to motions that contain excerpts from Jane Doe's deposition, all of which were filed under seal and subject to the Court's protective order. Two of the exhibits were filed in connection with Doe's class-certification motion. Mr. Staley takes no position on those, as they do not contain information relating to him. The other three were filed in connection with the parties' various motions for summary judgment, none of which were ruled upon by the Court. I Mr. Staley opposes the unsealing of these three exhibits. The Times fails to address the most on-point authority explaining that sealed filings associated with motions that have not and will never be decided are not "judicial documents" subject to the public's presumption of access. And even if they were judicial documents, under every relevant standard these documents should remain sealed. Each contains deposition testimony regarding Doe's allegation of assault against Mr. Staley. Mr. Staley has consistently and repeatedly denied those false allegations. Mor