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S.D.N.Y.Procedural orderFiled May 8, 2025

Stocking v. Newmark Knight Frank Valuation & Advisory, LLC

Judge
Edgardo Ramos
Docket
1:22-cv-07347
Court
U.S. District Court · Southern District of New York
Pages
5
Civil ProcedureDiscoveryPro Se
In one sentence

In Stocking v. Newmark, Judge Ramos ordered Newmark to respond by May 13 to Stocking’s motion to seal a letter.

Who this affects

Maria Stocking and Newmark Knight Frank Valuation & Advisory, LLC; the immediate issue concerned Stocking’s proposed sealed filing and Newmark’s response.

What happened

In Stocking v. Newmark Knight Frank Valuation & Advisory, LLC, Maria Stocking, representing herself, sought permission to file a letter under seal. She said cyberattacks had destroyed electronic information relevant to the case.

Stocking said the proposed letter would describe the alleged cyber harassment, lost data, account information, forensic findings, and recovery efforts. She argued that public disclosure could expose remaining information and unresolved security weaknesses.

Judge Edgardo Ramos did not decide the sealing request in this order. Instead, the court directed Newmark to respond by May 13, 2025.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Stocking v. Newmark Knight Frank Valuation & Advisory, LLC · No. 1:22-cv-07347
Judge
Edgardo Ramos
Date
May 8, 2025

Background

Maria Stocking, proceeding without a lawyer, filed a motion seeking permission to submit a letter under seal. The letter concerned Stocking’s alleged loss of electronically stored information relevant to the litigation. Stocking stated that a series of cyberattacks beginning on February 3, 2025, wiped information from her electronic devices and cloud storage systems, including communications and documents related to the case.

Stocking said she had previously informed Newmark about the cyberattacks and resulting data loss, including the possible loss of communications with her former lawyer, Stewart Karlin. According to Stocking, Newmark later accused her of misrepresentation concerning discovery materials while not disclosing its prior knowledge of the possible data loss.

Motion to Seal

Stocking’s proposed sealed letter would describe alleged cyber harassment involving her electronic filing email account, account-access information, forensic findings, intrusion methods, and containment and recovery efforts. She said the affected devices and storage media included two personal computers, mobile phones, USB drives, and cloud archives.

Stocking argued that public disclosure could create risks to surviving materials, ongoing containment efforts, and potential legal remedies involving digital evidence. Relying on the court’s electronic filing rules and the Second Circuit’s decision in Lugosch v. Pyramid Co. of Onondaga, she argued that the sensitive information justified sealing. She requested leave to file a sealed version together with a publicly accessible version containing redactions.

Court’s Action

The May 8, 2025 order did not grant or deny the motion to seal. Judge Edgardo Ramos directed Newmark to respond by May 13, 2025. The supplied text does not state a later ruling on whether the letter could be filed under seal.

The authoritative version

Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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