IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CBV, INC., Plaintiff, v. CHANBOND, LLC, DEIRDRE LEANE, and IPNAV, LLC, Defendants. ) ) ) ) C.A. No. 1:21-cv-01456-MN DEIRDRE LEANE AND IPNAV, LLC’S UNOPPOSED MOTION TO FILE UNDER SEAL Defendants Deirdre Leane and IPNAV, LLC (collectively, the “Leane Defendants”) respectfully move this Court pursuant to Federal Rule of Civil Procedure 5.2, and Local Rule 5.1.3 for entry of an order authorizing the Leane Defendants to file their Answer to Plaintiff CBV, Inc.’s (“CBV”) First Amended Complaint (D.I. 6) (including any counterclaims or crossclaims the Leane Defendants assert pursuant to Federal Rule of Civil Procedure 13) under seal. Plaintiff CBV and Defendant ChanBond, LLC do not oppose this relief.
On October 15, 2021, CBV filed a Motion to Seal the Complaint (D.I. 1). The Court granted CBV’s Motion to Seal on October 15, 2021 (D.I. 4). CBV subsequently filed a First Amended Complaint (D.I. 6) on December 6, 2021 under seal. The First Amended Complaint sets forth information regarding the parties’ confidential business information.
The Leane Defendants’ Answer to the First Amended Complaint will contain the same or similar confidential information. Accordingly, the Leane Defendants respectfully submit that good cause exists to seal their Answer to First Amended Complaint (including any counterclaims or crossclaims the Leane Defendants assert pursuant to Federal Rule of Civil Procedure 13) to protect the interests of one or more parties against public dissemination of the confidential information contained within the Leane Defendants’ Answer to First Amended Complaint, counterclaims, and/or crossclaims. The Leane Defendants will comply with all applicable local rules and procedures regarding filing under seal through the Court’s CM/ECF system, including the requirement to file a redacted version within seven (7) days of filing the sealed document. The Leane Defendants therefore respectfully request entry of the attached order permitting the filing of their Answer to CBV’s First Amended Complaint, and any counterclaims or crossclaims that they may file pursuant to Federal Rule of Civil Procedure 13, under seal.
OF COUNSEL: Akiva M. Cohen Dylan M. Schmeyer KAMERMAN, UNCYK, SONIKER & KLEIN P.C, 1700 Broadway, 16th Floor New York, NY 10019 212.400.4930 acohen@kusklaw.com dschmeyer@kusklaw.com
Dated: March 22, 2022 Respectfully submitted, /s/ James H. S. Levine James H. S. Levine (DE No. 5355) TROUTMAN PEPPER HAMILTON SANDERS LLP Hercules Plaza, Suite 5100 1313 N. Market Street P.O. Box 1709 Wilmington, DE 19899-1709 302.777.6500 james.levine@troutman.com Attorneys for IPNAV, LLC and Deirdre Leane
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