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Case 9:18-cv-80176-BB Document 367 Entered on FLSD Docket 01/09/2020 Page 1 of 2

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF FLORIDA

IRA KLEIMAN, as the personal representative CASE NO.: 9:18-cv-80176-BB/BR


of the Estate of David Kleiman, and W&K Info
Defense Research, LLC

Plaintiffs,

v.

CRAIG WRIGHT

Defendant.

PLAINTIFFS’ MOTION TO SEAL


In advance of today’s discovery hearing, Plaintiffs will be filing a Notice of Filing attaching

a third Tulip Trust document (“Tulip Trust III”) that was not produced under this Court’s prior

order to produce all documents related to the “blind” tulip trust (ECF No. [166]). Plaintiffs received

this document for the first time on January 6, 2020, amongst a production of 428 other documents,

without any explanation as to its late disclosure, or even an email pointing out this document had

been produced.

Craig has marked this Tulip Trust III document as “Confidential” pursuant to the Stipulated

Confidentiality Order. (ECF No. [105-1].) While Plaintiffs do not believe the Tulip Trust III

document should be sealed in its entirety, Plaintiffs believe Craig should be afforded the

opportunity to propose redactions to the Court.

Accordingly, Plaintiffs make this motion to seal to comply with the Stipulated Confidential

Order and the Local Rules of this Court.

WHEREFORE, Plaintiffs request Defendant be given 10 days to provide proposed

redactions to the Court.


Case 9:18-cv-80176-BB Document 367 Entered on FLSD Docket 01/09/2020 Page 2 of 2

Dated: January 9, 2020 Respectfully submitted,

s/ Velvel (Devin) Freedman


Velvel (Devin) Freedman, Esq.
ROCHE FREEDMAN LLP
200 S. Biscayne Blvd, Suite 5500
Miami, Florida 33131
Telephone: (305) 357-3861
vel@rochefreedman.com
nbermond@rochefreedman.com

Kyle W. Roche, Esq.


Joseph M. Delich, Esq.
Admitted Pro Hac Vice
ROCHE FREEDMAN LLP
185 Wythe Avenue F2
Brooklyn, NY11249
kyle@rochefreedman.com
jdelich@rochefreedman.com

Andrew S. Brenner, Esq.


BOIES SCHILLER FLEXNER LLP
100 SE 2nd Street, Suite 2800
Miami, Florida 33131
abrenner@bsfllp.com

Counsel to Plaintiffs Ira Kleiman as Personal


Representative of the Estate of David Kleiman and
W&K Info Defense Research, LLC.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on January 9, 2020, a true and correct copy of the foregoing
was filed with CM/ECF, which caused a copy to be served on all counsel of record.

/s/ Velvel (Devin) Freedman


Velvel (Devin) Freedman

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Case 9:18-cv-80176-BB Document 367-1 Entered on FLSD Docket 01/09/2020 Page 1 of 1

UNITED STATES DISTRICT COURT


SOUTHERN DISTRICT OF FLORIDA

IRA KLEIMAN, as the personal representative CASE NO.: 9:18-cv-80176-BB/BR


of the Estate of David Kleiman, and W&K Info
Defense Research, LLC

Plaintiffs,

v.

CRAIG WRIGHT

Defendant.

ORDER GRANTING PLAINTIFFS’ MOTION TO FILE UNDER SEAL

THIS CAUSE is before the Court on Plaintiffs’ Motion to File a notice of filing under seal.

The Court has reviewed the Motion, and being fully advised on the Motion, it is hereby:

ORDERED AND ADJUDGED that the Motion is GRANTED and that DEFENDANT

shall have until January 19, 2019 to propose redactions to the Tulip Trust III document attached

thereto.

DONE AND ORDERED in chambers on this ___ day of January 20, 2020.

______________________________
Judge Bruce Reinhart
United States Magistrate Judge

Copies furnished: All counsel of record