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Case 2:23-cv-01997-MCA-JSA Document 13 Filed 04/27/23 Page 1 of 2 PageID: 1216
`
`
`
`Liza M. Walsh
`Marc D. Haefner
`Selina M. Ellis
`WALSH PIZZI O’REILLY FALANGA LLP
`Three Gateway Center
`100 Mulberry Street, 15th Floor
`Newark, New Jersey 07102
`Tel.: (973) 757-1100
`
`Attorneys for Defendant Thermo Fisher Scientific
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
`
`
`
`Civil Action No. 2:23-cv-01997
`(MCA-JSA)
`
`NOTICE OF MOTION TO SEAL
`
`Filed Electronically
`
`
`
`
`
`
`
`
`MONIB ZIRVI, M.D., Ph.D.,
`
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`
`
`ILLUMINA, INC., THERMO FISHER SCIENTIFIC,
`AKIN GUMP STRAUSS HAUER & FELD LLP,
`LATHAM & WATKINS, RIP FINST, SEAN
`BOYLE, MATTHEW A. PEARSON, ANGELA
`VERRECCHIO, ROGER CHIN, and DOUGLAS
`LUMISH,
`
`
`Defendants.
`
`
`
`
`PLEASE TAKE NOTICE that on a date to be set by the Court, or as soon thereafter as
`
`counsel can be heard, the undersigned, attorneys for Defendant Thermo Fisher Scientific (“Thermo
`
`Fisher”) shall move before the Honorable Jessica S. Allen, U.S.M.J., at the United States District
`
`Court for the District of New Jersey, Martin Luther King, Jr. Building & U.S. Courthouse, 50
`
`Walnut Street, Newark, New Jersey, for the entry of an Order pursuant to Local Civil Rule
`
`5.3(c)(9) to seal the entirety of Exhibits 6, 7 and 8 attached to Plaintiff’s Complaint (D.E. 1).
`
`
`
`

`

`Case 2:23-cv-01997-MCA-JSA Document 13 Filed 04/27/23 Page 2 of 2 PageID: 1217
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`PLEASE TAKE FURTHER NOTICE THAT Thermo Fisher shall rely upon the
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`accompanying Proposed Findings of Fact and Conclusions of Law, Declaration of Liza M.
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`Walsh with Exhibit 1 annexed thereto; and all papers submitted herewith.
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`PLEASE TAKE FURTHER NOTICE THAT Thermo Fisher requests that the Court
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`unseal the Letter to the Hon. Madeline Cox Arleo, U.S.D.J. and to the Hon. Jessica S. Allen,
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`U.S.M.J., dated April 12, 2023 (D.E. 7).
`
`PLEASE TAKE FURTHER NOTICE THAT a proposed form of Order is also
`
`
`
`
`
`
`Respectfully, submitted,
`
`By: s/Liza M. Walsh
`Liza M. Walsh
`Marc D. Haefner
`Selina M. Ellis
`WALSH PIZZI O’REILLY FALANGA LLP
`Three Gateway Center
`100 Mulberry Street, 15th Floor
`Newark, NJ 07102
`(973) 757-1100
`
`Attorneys for Defendant
`Thermo Fisher Scientific
`
`
`
`
`
`
`submitted for the Court’s consideration.
`
`
`Dated: April 27, 2023
`
`
`
`
`
`
`
`
`
`
`
`2
`
`

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