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Civil Rights: Employment | Pennsylvania Eastern
Leave to File Document
MOTION for Leave to File Under Seal Certain Portions of and Exhibits to Drexel's Opposition to Plaintiff's Motion to Compel Discovery - Alleged Privilege Documents, Statements/Testimony of Nicole Sugarman (ECF Doc. No. 35) and Drexel's Cross-Motion to Find Plaintiff's Counsel in Civil Contempt and for Sanctions filed by DREXEL UNIVERSITY.Memorandum, Certificate of Service. (Attachments: # 1 Text of Proposed Order on Motion for Leave to File Under Seal Certain Portions of and Exhibits to Defendant's Opposition to Plaintiff's Motion to Compel, # 2 Memorandum of Law in Support of Motion for Leave to File Under Seal, # 3 Text of Proposed Order on Plaintiff's Motion to Compel and Defendant's Cross-Motion, # 4 Memorandum of Law in Opposition to Plaintiff's Motion to Compel and in Support of Drexel's Cross-Motion to Find Plaintiff's Counsel in Civil Contempt and for Sanctions (with proposed redactions), # 5 Exhibit 1 to Drexel Opposition to Plaintiff Motion to Compel - N. Sugarman Deposition Transcript (with proposed redactions), # 6 Exhibit 2 to Drexel Opposition to Plaintiff Motion to Compel - Dec. 8-20, 2023 Email Chain (with proposed redactions), # 7 Exhibit 3 to Drexel Opposition to Plaintiff Motion to Compel - Feb. 13, 2024 Email Chain (with proposed redactions), # 8 Exhibit 4 to Drexel Opposition to Plaintiff Motion to Compel - Feb. 14-27, 2024 Email Chain, # 9 Exhibit 5 to Drexel Opposition to Plaintiff Motion to Compel - June 22, 2026 Email from Judge Wolson Chambers)(BIEMILLER, CHELSEA)
Memorandum
Memorandum re 38 MOTION to Seal Document 35 MOTION to Compel Alleged Privileged Information Refiled Brief filed by KIM P. GUNTER. (Attachments: # 1 Certificate of Service, # 2 Exhibit B: May 20, 2026 Sugarman Deposition Transcript Excerpts (Redacted), # 3 Exhibit C: Kim Gunter's February 20 & 27, 2024 Personal Notes (Redacted), # 4 Exhibit E: Privilege Logs with Respective Exhibits (Redacted), # 5 Exhibit AA: Affidavit of Karin M. Gunter, Esquire, # 6 Exhibit AA Exhibit 1: March 4, 2024 Email Thread Kim Gunter to Helen Bowman, # 7 Exhibit AA Exhibit 2: June 12, 2026 Letter from Yuliya Khromyak, Esquire, # 8 Exhibit BB: Affidavit of Yuliya Khromyak, Esquire)(GUNTER, KARIN)
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