Case 19-1540, Document 172-1, 09/11/2019, 2653049, Page1 of 2
UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT
Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500
MOTION INFORMATION STATEMENT
Docket Numbe r(s): 19-1540-cv

Caption fuse short titlel

Motion for: Motion to Intervene & Unseal Judicial
Records
DONALD J. TRUMP, et al.

v.
Set forth below precise, complete statement of relief sought

DEUTSCHE BANK AG, et al.

The Media Coalition seeks to intervene for the limited
purpose of enforcing the public's First Amendment
and common law rights of access to judicial records and
to unseal the names currently redacted in Deutsche
Bank's August 27, 2019 Letter to the Clerk (Dkt. 161).

MOVING PARTY: See attached Addendum

OPPOSING PARTY: See Certification in supporting memorandum

Plaintiff

Defendant

Appellant/Petitioner

Appellee/Respondent

MOVING ATTORNEY:

Jacquelyn N. Schell

OPPOSING ATTORNEY:
[name of attorney, with firm, address, phone number and e-mail]

BALLARD SPAHR LLP
1675 Broadway, 19th Floor
New York, NY 10019
Court- Judge/ Agency appealed from: Southern District of New York - Ramos, J.
Please check appropriate boxes:
Has movant notified opposing counsel (required by Local Rule 27.1):
V Yes
No (explain):

FOR EMERGENCYMOTIONS, MOTIONS FOR STAYS AND
INJUCTIONS PENDING APPEAL:
Has this request for relief been made below?
es
Has this relief been previously sought in this court?
Yes
Requested return date and explanation of emergency:

** Opposing counsel's position on motion:
Unopposed be Opposed
Don't Know
Does opposing counsel intend to file a response:
Yes
No se Don't Know

Is oral argument on motion requested?

Yes V No (requests for oral argument will not necessarily be granted)

Has argument date of appeal been set?

Yes

No If yes, enter date: August 23, 2019

Signature of Moving Attorney:

/s/ Jacquelyn N. Schell

Date: 9/11/2019

**See Certification in supporting memorandum
Form T-1080 (rev.12-13)

Service by:

✓ CM/ECF

Other [Attach proof of service]

 Case 19-1540, Document 172-1, 09/11/2019, 2653049, Page2 of 2

ADDENDUM
Moving Intervenors:
The Associated Press,
Cable News Network, Inc.,
The New York Times Co.,
POLITICO LLC and
WP Co., LLC, d/b/a the Washington Post