On May 11, 2018 a
Letter,Correspondence
was filed
involving a dispute between
Stella Stolper,
and
Zarina Burbacki,
for Commercial Division
in the District Court of New York County.
Preview
KRUZHKOV RUSSO 350 Fifth Avenue
Suite 7230New Yo rk NY 10118
PLL C 212 363 2000 kru zhkovrusso.com
November 21, 2019
VIA ECF
Hon. Justice Borrok
Supreme Court of the State of New York
Commercial Division
60 Centre Street, Courtroom 238
New York, NY 10007
Re: Stella Stolper v. Zarina Burbacki Index no. 652352/2018
Dear Justice Borrok:
We represent Plaintiff Stella Stolper in the above-referenced action. This letter is
written jointly on behalf of counsel for all parties to the action.
As the Court is aware, Plaintiff currently has an Order to Show Cause pending
before the Court with a return date of December 6, 2019 (“OSC”). Defendant’s counsel
has informed us that he intends to file papers opposing the OSC by the stated deadline of
November 22, 2019.
Counsel has informed us that Defendant’s opposition to the OSC is at least
partially based on the contents of a settlement agreement between Plaintiff and non-party,
Mariah Carey (“MC”), that was produced and designated as containing “Attorney’s Eyes
Only” information, in accordance with the Stipulation and Order for the Production and
Exchange of Confidential Information signed by the parties on August 14, 2019.
Plaintiff is of the opinion that due to the highly sensitive nature of the settlement
agreement and MC’s standing as a celebrity, the settlement agreement and any discussion
of it should be filed under seal. Defendant’s counsel has agreed that he will not oppose an
application by Plaintiff to seal such Attorney’s Eyes Only information. In order to save
time and reduce the costs of litigation, we hereby request that the Court issue a protective
order allowing Defendant’s opposing papers, our reply and any other papers pertinent
thereto, to be filed on November 22, 2019 under seal in accordance with the procedures
that govern the filing of sealed documents on the NYCEF.
Respectfully submitted,
/s/ Marlen Kruzhkov
Marlen Kruzhkov, Esq.
Counsel for Plaintiff Stella Stolper
Enclosure
Cc: All counsel of record (via ECF)
Document Filed Date
November 21, 2019
Case Filing Date
May 11, 2018
Category
Commercial Division
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KRUZHKOV RUSSO 350 Fifth Avenue Suite 7230New Yo rk NY 10118 PLL C 212 363 2000 kru zhkovrusso.com November 21, 2019 VIA ECF Hon. Justice Borrok Supreme Court of the State of New York Commercial Division 60 Centre Street, Courtroom 238 New York, NY 10007 Re: Stella Stolper v. Zarina Burbacki Index no. 652352/2018 Dear Justice Borrok: We represent Plaintiff Stella Stolper in the above-referenced action. This letter is written jointly on behalf of counsel for all parties to the action. As the Court is aware, Plaintiff currently has an Order to Show Cause pending before the Court with a return date of December 6, 2019 (“OSC”). Defendant’s counsel has informed us that he intends to file papers opposing the OSC by the stated deadline of November 22, 2019. Counsel has informed us that Defendant’s opposition to the OSC is at least partially based on the contents of a settlement agreement between Plaintiff and non-party, Mariah Carey (“MC”), that was produced and designated as containing “Attorney’s Eyes Only” information, in accordance with the Stipulation and Order for the Production and Exchange of Confidential Information signed by the parties on August 14, 2019. Plaintiff is of the opinion that due to the highly sensitive nature of the settlement agreement and MC’s standing as a celebrity, the settlement agreement and any discussion of it should be filed under seal. Defendant’s counsel has agreed that he will not oppose an application by Plaintiff to seal such Attorney’s Eyes Only information. In order to save time and reduce the costs of litigation, we hereby request that the Court issue a protective order allowing Defendant’s opposing papers, our reply and any other papers pertinent thereto, to be filed on November 22, 2019 under seal in accordance with the procedures that govern the filing of sealed documents on the NYCEF. Respectfully submitted, /s/ Marlen Kruzhkov Marlen Kruzhkov, Esq. Counsel for Plaintiff Stella Stolper Enclosure Cc: All counsel of record (via ECF)