Opinion

| UsDC SDNY

HBOCU MENT

A eELECTRONICALLY FILED

ALSTON&BIRD:

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212-210-9400 | Fax: 212-210-9444

Eric Kuwana Direct Dial: 212-210-9586 Email: eric.kuwana@alston.com

May 12, 2026

VIA ECF

The 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 10017-1312

Re: Edmar Fin. Co., LLC, et al. v. Currenex, Inc., et al., Case No. 21-cv-06598

Dear Judge Kaplan,

We represent Defendants Currenex, Inc., State Street Bank and Trust Company,

and State Street Global Markets International Limited in the above matter. We write on

behalf of all Defendants in advance of filing a response to Plaintiffs’ request for an

extension of their deadline to disclose rebuttal merits expert reports (the “Response’’). ECF

No. 465.

Pursuant to Federal Rule of Civil Procedure 5.2(d), this Court’s Rules, the

Stipulation and Order of Confidentiality so ordered in this action on October 18, 2023,

(ECF No. 113), and the Joint Stipulation and Order Regarding Class Certification Sealing

and Page Limits so ordered in this action on November 13, 2025 (the “Sealing Order”)

(ECF No. 387), Defendants respectfully submit this letter motion to request that Exhibit B

to Defendants’ forthcoming Response be filed under seal. Exhibit B contains excerpts from

the transcript of the February 6, 2026 deposition of Peter Reiss, Defendants’ damages

expert, which was previously sealed pursuant to the Court’s March 2, 2026 Order (ECF

No. 458). The deposition transcript has also been designated as Highly Confidential

pursuant to the Parties’ Stipulation and Order of Confidentiality. See ECF No. 113.

This deposition transcript reflects Defendants’ commercially sensitive and

proprietary information. Defendants respectfully submit that sealing is justified under

controlling legal precedent. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120

(2d Cir. 2006).

Artal

‘lh

LEWIS A. KAPLAN, USDJ

Hon. Lewis A. Kaplan, U.S.D.J.

May 12, 2026

Page 2

As always, we thank the Court for its attention to this matter.

Respectfully submitted,

/s/ Eric Kuwana

Eric Kuwana

cc: All Counsel of Record (via ECF)