Iowa Public Employees' Retirement System v. Bank of America Corporation

Plaintiffs’ letter-motion to seal (ECF No. 500) is GRANTED.

quinn emanuel trial lawyers | new york The Clerk of Court is respectfully directed to limit access to

ECF No. 501 to the case participants and Court users.

Plaintiffs shall promptly file on ECF a redacted version of

their letter filed at ECF No. 501.

November 29, 2021 SO ORDERED 11/30/2021

VIA ECF . ip

LX } LAA 7

Magistrate Judge Sarah L. Cave eu

Daniel Patrick Moynihan Courthouse ~United States Magistrate Judge

500 Pearl Street, Room 1670

New York, NY 10007

Re: Jowa Pub. Emps.’ Ret. Sys. et al. v. Bank of Am. Corp. et al., No. 17-cv-6221 (KPF-SLC)

Dear Judge Cave:

Plaintiffs respectfully request leave to file their letter-reply in support of Plaintiffs’

letter-motion for extension of time to file a response to Defendants’ sur-reply (ECF 495, 498)

with redactions to references to confidential material, pursuant to paragraph I.G of this Court’s

Individual Rules of Practice.

Plaintiffs request to file their letter-reply in redacted form as it contains references to

expert materials and documents that have already been, or will be, filed under seal or in

redacted form pursuant to sealing orders issued by Judge Failla and have been designated as

Highly Confidential or Confidential pursuant to the Protective Order in this case (ECF 150).

See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (recognizing that

the Court must “balance competing considerations against [the presumption of access],”

including but not limited to “the privacy interests of those resisting disclosure”) (quoting

United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995)).

Respectfully submitted,

/s/ Michael B. Eisenkraft /s/ Daniel L. Brockett

Michael B. Eisenkraft Daniel L. Brockett

COHEN MILSTEIN SELLERS & TOLL QUINN EMANUEL URQUHART &

PLLC SULLIVAN, LLP