irst, courts in this Circuit have routinely ordered unsealing of documents in cases with protective orders or confidentiality provisions. See, e.g., Gambale v. Deutsche Bank AG, 377 F.3d 133, 143 (2d Cir. 2004) (unsealing judicial document despite party's claim that it had settled claim to "avoid public

a July 29, 2020 Page 2 courts have recognized, temporary stays of unseal orders are appropriate so that "[t]he genie is [not] out of the bottle," Gambale v. Deutsche Bank AG, 377 F.3d 133, 144 (2d Cir. 2004), before the interested parties have an opportunity to seek review of the orders. See, e.g., Un

sistance to discovery on grounds of privacy, confidentiality, secrecy, sensitivity and embarrassment. Even if Lugosch could overrule Martindell and Gambale with respect to the strong presumption against access when there is reasonable reliance on a protective order, the Lugosch 5In Lugosch, this Court

ng confidential materials to non-parties, it is not reasonable for a party to rely on an assumption that it will never be modified."). The court in Gambale came to a similar conclusion—holding that parties cannot rely on protective orders that arc on their face temporary. See Gambale, 377 F.3d at 142 n