Allianz Global Investors GmbH v. Bank Of America Corporation

King & Spalding LLP KING & SPALDING ring & Spalding ITP NW Suite 200 Washington, D.C. 20006-4707 Tel: +1 202 737 0500 een Fax: +1 202 626 3737 i USDC SDNY www kslaw.com | DOCUMENT Patrick Montgomery Partner ELECTRONICALLY FILED Direct Dial: +1202 626 5444 DOC #: [email protected] 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 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 [email protected] Counsel for Defendants Deutsche Bank AG and Deutsche Bank Securities Inc .