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Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 23 of 32 memorandum of law” seeking to limit discovery “clearly constitute ‘judicial documents’”); Jn re Omnicom Grp., Inc. Secs. Litig., No. 02 Civ. 4483, 2006 WL 3016311, at *2 (S.D.N.Y. Oct. 23, 2006) (holding that letter briefs and attached exhibits submitted to the court in connection with a privilege dispute were “submitted in this case to request the court to exercise its adjudicative powers in favor of the parties’ respective views of a discovery dispute” and therefore were judicial documents); Schiller, 2006 WL 2788256, at *5 (holding that briefs and supporting papers submitted in connection with a dispute over the confidentiality of discovery materials were “created by or at the behest of counsel and presented to a court in order to sway a judicial decision” and were therefore “judicial documents that trigger the presumption of public access”); S.E.C. v. Oakford Corp., No. 00 Civ. 2426, 2001 WL 266996, at *1 (S.D.N.Y. Mar. 16, 2001) (applying presumption of access to judicial documents to motion papers filed in connection with a discovery dispute); see also In re Gushlak, No. 11-MC-0218, 2012 WL 3683514, at *3 (E.D.N.Y. July 27, 2012) (holding that documents filed in support of and opposition to a motion for discovery assistance, including motions to quash, were judicial documents). The Requested Documents were submitted to the Court to influence its adjudication of the motion to quash and the motion to extend the deposition deadline, and they are therefore judicial documents. Cc. The Common Law Right of Access Applies to the Requested Documents 1. The Weight of the Presumption of Access Is Strong Treating materials submitted in connection with a discovery motion as judicial documents that the public may presumptively access gives effect to the purposes of the common law right, which is to facilitate public monitoring of the exercise of judicial power. “Monitoring both provides judges with critical views of their work and deters arbitrary judicial behavior.” Amodeo II, 71 F.3d at 1048. 17