Allianz Global Investors GmbH v. Bank Of America Corporation

GIBSON DUNN Gibson, Dunn & Crutcher LLP New ‘ork ‘ol 66-0193 Tel 212.351.4000 en www. gibsondunn.com USDC SDNY Eric J. Stock Direct: +1 242.351.2301 DOCUMENT Fax: #1 212.716.0801 ELECTRONICALLY FILED momnegnsonaun □□ DOC #: VIA ECF Hon. Stewart D. Aaron United States District Court for the Southern District of New York Pearl Street New York, New York 10007 Re: Allianz Global Investors GmbH, et al. v. Bank of Am. Corp., et al., 1:18-cv-10364 Dear Judge Aaron: Pursuant to Section I(B)(3) of Your Honor’s Individual Practices, we respectfully seek leave to file under seal unredacted versions of certain supporting papers and exhibits to Defendants UBS AG and UBS Securities LLC’s (collectively the “UBS Defendants”) Motion for Issuance of Hague Convention Request for International Judicial Assistance to Obtain Evidence in the United Kingdom and Hong Kong. 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 the Parties produced and designated as Confidential or Highly Confidential under the Protective Order, and personal information about the proposed deponents.

Given that the Parties designated these materials as Confidential or Highly Confidential, and personal information of the deponents is contained within these papers, the UBS Defendants respectfully request that the Court grant the UBS Defendants permission to file the requested documents in redacted form on ECF and in unredacted form under seal.

June 22, 2022 Page 2 Respectfully Submitted, By: /s/ Eric J. Stock Eric J. Stock Philip O. Shapiro Gibson, Dunn & Crutcher LLP Park Avenue New York, New York 10166 United States of America Telephone: +1 (212) 351-2301 Email: [email protected] Counsel for Defendants UBS AG and UBS Securities LLC Request GRANTED. The proposed sealing requests are narrowly tailored to prevent unauthorized dissemination of sensitive business information. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). SO ORDERED.

Dated: June 23, 2022 Arr