Opinion

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DOCUMENT

ELECTRONICALLY FILED |

DOC #: | WRITER’S DIRECT DIAL|NO.

a (212) 849-7345

DATE FILED:

| WRITER’S EMAIL ADDRESS

| cues

October 28, 2025

By ECF

Honorable Lewis A. Kaplan

United States District Judge

Southern District of New York

Daniel Patrick Moynihan

United States Courthouse

500 Pearl Street

Court Room 21B

New York, NY 10007-1312

Re: Edmar Financial Company, LLC et al v. Currenex, Inc. et al, Case No. 21-cv-06598 |

Plaintiffs’ Response to Defendants’ Letter Motion to Seal (ECF No. 354)

Dear Judge Kaplan:

On behalf of Plaintiffs, we respectfully submit this response to request three exhibits and the

relevant portions of Defendants’ response filed at ECF No. 355 (the “Response”) remain under

seal. See ECF Nos. 354 (letter motion to seal), 355 (Response referencing Exhibits), and 35 St,

355-2, and 355-3 (the “Exhibits” at issue).

We designated the Exhibits as “Highly Confidential” pursuant to the Court’s Protective nie,

ECF No. 113, because they include information concerning confidential and non-public

communications regarding potential litigation. Documents should remain sealed if “closure is

essential to preserve higher values and is narrowly tailored to serve that interest.” Lugosch v.

Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (citation omitted). There is

significant public interest in maintaining the confidentiality of communications between attorney

and client and “this is precisely the kind of countervailing concern that is capable of cole

the general preference for public access to judicial records.” Diversified Grp., Inc. v. Daugerdas,

217 F.R.D. 152, 160 (S.D.N.Y. 2003) (citation omitted). Plaintiffs also seek to avoid any iba

of the confidentiality of communications involving law firms not present in the case. For all the

reasons set forth above, the Court should order that the Exhibits and references in Defendants’

Response remain sealed.

quinn emanuel urquhart & sullivan, lip

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Respectfully submitted,

/s/ Daniel L. Brockett

Daniel L. Brockett

cc: Counsel of Record