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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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` Hon. Edmond E. Chang
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` Case No. 15 CR 620-2
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`UNITED STATES OF AMERICA,
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`Plaintiff,
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`BARBARA BYRD-BENNETT, GARY
`SOLOMON, THOMAS VRANAS, THE SUPES
`ACADEMY, LLC, and SYNESI ASSOCIATES,
`LLC,
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` Defendants.
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`MOTION TO FILE EXHIBIT UNDER SEAL
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`On September 5, 2017, Defendant Gary Solomon (“Solomon”) filed his Motion
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`to Amend Judgment (Dkt. 152), and in support of that Motion, provided an
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`affidavit. Pursuant to Local Rule 26.2, Solomon contemporaneously moves this
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`Court to allow him to file his affidavit, which constitutes Exhibit A to the
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`Motion to Amend Judgment, under seal. In support of this Motion, Solomon
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`states as follows:
`1. On September 5, 2017, Solomon filed his Motion to Amend Judgment,
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`specifically to request that the Court provide an explanation for its recommendation
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`to designate Solomon to the federal facility located in Oxford, Wisconsin.
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`2. Solomon supported his request by providing an affidavit that more fully
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`explained the relevant details. However, that affidavit also included the private
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`medical information of a number of third parties, who are not part of these
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`Case: 1:15-cr-00620 Document #: 155 Filed: 09/05/17 Page 2 of 3 PageID #:4634
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`proceedings. Those third parties and their medical information is readily identifiable
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`in Solomon’s affidavit.
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`3. Accordingly, to protect the privacy of those third parties, Solomon
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`requests that this Court grant an order allowing his to file his affidavit under seal.
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`WHEREFORE, Gary Solomon respectfully requests that this Court enter an
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`order allowing him to file his affidavit in support of his Motion to Amend Judgment
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`under seal, and for such other and further relief that this Court deems just.
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`Mark A. Flessner
`Trisha M. Rich
`Lisa M. Kpor
`Holland & Knight LLP
`131 S. Dearborn St., 30th Floor
`Chicago, Illinois 60603
`(312) 263-3600
`mark.flessner@hklaw.com
`trisha.rich@hklaw.com
`lisa.kpor@hklaw.com
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`Respectfully submitted,
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`GARY SOLOMON,
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`By:/s/ Trisha M. Rich
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` One of his Attorneys
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`Case: 1:15-cr-00620 Document #: 155 Filed: 09/05/17 Page 3 of 3 PageID #:4635
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`/s/ Trisha M. Rich
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on September 5, 2017 the foregoing
`Motion to File Exhibit Under Seal was served via electronic mail to all counsel
`of record, and filed with Clerk of the Court for the Northern District of Illinois using
`the CM/ECF System, which automatically transmitted a Notice of Electronic Filing
`to all ECF registrants.
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