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| DOCUMENT Patrick Montgomery
Partner
ELECTRONICALLY FILED Direct Dial: +1202 626 5444
DOC #: pmontgomery@kslaw.com
DATE FILED: 06/16/2022
Request GRANTED. The proposed sealing requests
are narrowly tailored to prevent unauthorized
June 15, 2022 dissemination of sensitive business information. See
VIA ECF Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110,
119-20 (2d Cir. 2006). SO ORDERED.
Dated: June 16, 2022
Hon. Stewart D. Aaron A SC
United States District Court for the Southern District of New York
500 Pearl Street
New York, New York 10007
Re: Allianz Global, et al. v. Bank of Am. Corp., et al., 1:18-cv-10364
Dear Judge Aaron:
Pursuant to Section II(B)(3) of Your Honor’s Individual Practices, I write to seek leave to
file under seal unredacted versions of certain supporting papers and exhibits to Defendants’
Unopposed Motion for Issuance of a Hague Convention Request for International Judicial
Assistance to Obtain Evidence in Denmark. These papers have been publicly filed with redactions,
and unredacted versions are filed contemporaneously herewith under seal, accessible to counsel of
record for the parties in this action.
This request asks the Court to seal documents that include or quote from chat transcripts
and other documents that Plaintiffs produced and designated as confidential, and personal
information about the proposed deponents. Given Plaintiffs designated these materials as
“confidential,” supporting papers include documents already filed under seal, and personal
information of the deponents are contained within these papers, Deutsche Bank respectfully
requests that the Court grant Deutsche Bank permission to file the requested documents in redacted
form on ECF and in unredacted form under seal.
Respectfully Submitted,
/s/ G. Patrick Montgomery
G. Patrick Montgomery (pro hac vice)
1700 KING & SPALDING LLP
1700 Pennsylvania Ave., N.W.
Washington, DC 20006
Telephone: (202) 626-5444
pmontgomery@kslaw.com
Counsel for Defendants Deutsche Bank AG
and Deutsche Bank Securities Inc
.