`
`
`
`Joseph D. Garrity, Esq.
`101 N.E. THIRD AVENUE, SUITE 1800
`FORT LAUDERDALE, FLORIDA 33301
` (954) 462-8000
`www.loriumlaw.com
`
`
`November 14, 2023
`
`VIA E-FILING
`Honorable Madeline Cox Arleo, U.S.D.J.
`Honorable Jessica S. Allen, U.S.M.J.
`U.S. District Court for the District of New Jersey
`Martin Luther King Jr. Building & U.S. Courthouse
`50 Walnut Street
`Newark, New Jersey 07102
`
`Re: Monib Zirvi, M.D., Ph.D. v. Illumina, Inc. et al.
`
`
`Civil Action No.: 23-1997-MCA/JSA
`
`
`Your Honor Judge Allen,
`
`This letter is regarding the filing of the enclosed copy of Plaintiff’s Combined Verified Response
`
`Brief (EFC No. 107) in Opposition to Illumina (ECF No. 99) and Thermo Fisher Scientific’s (ECF No.
`104) Motion for Rule 11 Sanctions. After several attempts to review Exhibit 7 to determine if any of the
`Exhibit would fall under the spirit of the Court’s ruling regarding the sealing of certain communications
`a decision was made to seal the exhibit which has been provided to Opposing Counsels on this day.
`
`Unfortunately, the size of Exhibit 7, over 1600 pages of email correspondence, delayed the
`
`ultimate filing until early this morning after it became apparent it would be impossible to determine what
`should be sealed and what should not be sealed, given prior rulings. In an abundance of caution, we
`decided to seal the entire Exhibit 7, and address the request to seal in a subsequent filing as required.
`
`We respectfully request that the Court receive Plaintiff’s Combined Verified Response Brief
`
`(EFC No. 107) in Opposition to Illumina (ECF No. 99) and Thermo Fisher Scientific’s (ECF No. 104)
`Motion for Rule 11 Sanctions as timely filed and that the Court finds that Exhibit 7 be sealed until further
`Order of the Court. Alternatively, should the Court require further briefing on the issue, Plaintiff requests
`leave to file the same.
`
`WHEREFORE, Plaintiff specifically requests the Response and Exhibits be deemed accepted
`by the Court as filed and that Exhibit 7 be deemed filed under seal until further order of the Court.
`
`
`Sincerely,
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Joseph D. Garrity, Esq.
`For The Firm
`
`LORIUM LAW
`
`ATLANTA BOCA RATON CHICAGO FT. LAUDERDALE
`
`
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`
`
`
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