`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF VIRGINIA
`ALEXANDRIA DIVISION
`
`RAI STRATEGIC HOLDINGS, INC. and
`R.J. REYNOLDS VAPOR COMPANY,
`
`
`Plaintiffs and Counterclaim
`Defendants,
`
`v.
`
`
`
`
`ALTRIA CLIENT SERVICES LLC; PHILIP
`MORRIS USA INC.; and PHILIP MORRIS
`PRODUCTS S.A.
`
`Defendants and Counterclaim
`Plaintiffs.
`
`Civil Action No. 1:20-cv-393-LO-TCB
`
`
`
`COUNTERCLAIM PLAINTIFFS’ NOTICE OF A MOTION TO SEAL
`
`Pursuant to Local Civil Rule 5(C), Counterclaim Plaintiffs Altria Client Services, LLC
`
`(“ACS”), Philip Morris USA Inc. (“PM USA”), and Philip Morris Products S.A. (“PMP”)
`
`(collectively, “Counterclaim Plaintiffs”) hereby provide notice that they are filing a Motion to
`
`Seal. The Motion to Seal is being filed concurrently with, and in relation to, Counterclaim
`
`Plaintiffs’ Memorandum in Support of Their Motion to Compel Reynolds’ 30(b)(b) Deposition on
`
`Topics 28, 54, and 78, and exhibits 1-23 thereto.
`
`Memoranda in support of or in opposition to the Motion to Seal may be submitted by parties
`
`and non-parties within seven (7) days after the filing of the Motion to Seal. All or part of any such
`
`memoranda may be designated as confidential. Any information designated as confidential in a
`
`supporting or opposing memorandum will be treated as sealed pending a Case determination by
`
`the Court on the Motion to Seal. Any person objecting to the Motion to Seal must file an objection
`
`with the Clerk within seven (7) days after the filing of the Motion to Seal. If no objection is filed
`
`1
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 546 Filed 04/09/21 Page 2 of 3 PageID# 11686
`
`in a timely manner, the Court may treat the motion as uncontested.
`
`
`
`Dated: April 9, 2021
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`
`By: /s/ Maximilian A. Grant
`Maximilian A. Grant (VSB No. 91792)
`(max.grant@lw.com)
`Lawrence J. Gotts (VSB No. 25337)
`lawrence.gotts@lw.com
`Matthew J. Moore (pro hac vice)
`matthew.moore@lw.com
`LATHAM & WATKINS LLP
`555 Eleventh Street, N.W., Suite 1000
`Washington, DC 20004
`Telephone: (202) 637-2200
`Facsimile: (202) 637-2201
`
`Clement J. Naples (pro hac vice)
`clement.naples@lw.com
`LATHAM & WATKINS LLP
`885 Third Avenue
`New York, NY 10022-4834
`Tel: (212) 906-1200; Fax: (212) 751-4864
`
`Gregory J. Sobolski (pro hac vice)
`greg.sobolski@lw.com
`LATHAM & WATKINS LLP
`505 Montgomery Street, Suite 2000
`San Francisco, CA 94111
`Telephone: (415) 391-0600
`Facsimile: (415) 395-8095
`
`Brenda L. Danek (pro hac vice)
`brenda.danek@lw.com
`LATHAM & WATKINS LLP
`330 North Wabash Avenue, Suite 2800
`Chicago, IL 60611
`Tel: (312) 876-7700; Fax: (312) 993-9767
`
`Counsel for Defendants-Counterclaim Plaintiffs
`Altria Client Services LLC, Philip Morris USA
`Inc., and Philip Morris Products S.A.
`
`
`
`Case 1:20-cv-00393-LO-TCB Document 546 Filed 04/09/21 Page 3 of 3 PageID# 11687
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that on this 9th day of April, 2021, a true and correct copy of the foregoing
`
`was served using the Court’s CM/ECF system, with electronic notification of such filing to all
`
`counsel of record:
`
`
`
`
`
`/s/ Maximilian A. Grant
`Maximilian A. Grant (VSB No. 91792)
`LATHAM & WATKINS LLP
`555 Eleventh Street, N.W., Suite 1000
`Washington, DC 20004
`Telephone: (202) 637-2200
`Facsimile: (202) 637-2201
`Email: max.grant@lw.com
`
`
`Counsel for Defendants-Counterclaim
`Plaintiffs Altria Client Services LLC, Philip
`Morris USA Inc., and Philip Morris
`Products S.A.
`
`
`
`
`
`
`
`3
`
`
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