GOODSTADT □□□ Fl ATTORNEYS AT LAW 520 Eighth Avenue, 14th FI LAW GROUP. PLLC New York, New York 10 T: 646.430.8295 F: 646.430.8 USDC SDNY DOCUMENT Long Isle ELECTRONICALLY FILED 910 Franklin Avenue, Suite | DOC #: Garden City, New York 11. T: 516.307.1880 □□ □□□□□□□□□ George D. Vallas DATE FILED: 3/15/2021 ___ [email protected]

March 12,200 MEMO ENDORSED

VIA ECF Honorable Valerie E. Caproni United States District Court Southern District of New York 40 Foley Square, Room 240 New York, New York 10007

Re: Abromavage v. Deutsche Bank Securities Inc, et al., 18-cv-06621 (VEC)

Dear Judge Caproni: We represent Plaintiff in the above-referenced matter. In accordance with the Court’s February 23, 2021 Order (ECF No. 84), we respectfully submit revised versions of certain documents initially filed in connection with Plaintiff's Opposition to Defendants’ Motion for Summary Judgment, limiting the redactions of investigative material to entries that could reasonably be used to determine the identity of non-party interviewees. In particular, the following revised documents are annexed hereto: e Plaintiff's Rule 56.1 Counter-Statement of Disputed and Undisputed Material Facts in Opposition to Defendants’ Motion for Summary Judgment (ECF No. 72)

e Exhibit 19 to the Declaration of Andrew Goodstadt (ECF No. 74-19);

e Exhibit 23 to the Declaration of Andrew Goodstadt (ECF No. 74-23);

e Exhibit 26 to the Declaration of Andrew Goodstadt (ECF No. 74-26);

e Exhibit 27 to the Declaration of Andrew Goodstadt (ECF No. 74-27);

GOODSTADT ATTORNEYS AT LAW LAW GROUP, PLLC

Honorable Valerie E. Caproni March 12, 2021 Page 2

e Exhibit 55 to the Declaration of Andrew Goodstadt (ECF No. 74-55);

e Exhibit 56 to the Declaration of Andrew Goodstadt (ECF No. 74-56);

e Exhibit 57 to the Declaration of Andrew Goodstadt (ECF No. 74-57);

e Exhibit 58 to the Declaration of Andrew Goodstadt (ECF No. 74-58);

e Exhibit 59 to the Declaration of Andrew Goodstadt (ECF No. 74-59).

We thank the Court of its continued attention to this matter.

Respectfully submitted, | ai ii hl ff MY | |i | Plaintiff and Defendants’ revised requests to seal are hereby i | |] ws GRANTED. See Dkts. 87, 88. The narrower redactions □□□□ \ © Vallas with the strong presumption of public access that applies to Judicial documents, such as those at issue here. See Lugosch \ Pyramid Co. of Onondaga,

(2d Cir. 2006). Enel The Clerk of Court is respectfully directed to close the open motion at docket entry 87. SO ORDERED. □□ cs March 15, 2021 HON. VALERIE CAPRONI UNITED STATES DISTRICT JUDGE