HOLWELL SHUSTER & GOLDBERG ur» 425 Lexington Avenue New York, New York 10017 Tel: (646) 837-5151 Fax: (646) 837-5150 www.hsgllp.com Vincent Levy (646) 837-5120 MEMO ENDOF [email protected] July 21, 2022 VIA ECF spc spny Hon. Louis L. Stanton DOCUMENT United States District Judge ELECTRONICALLY FIL Daniel Patrick Moynihan United States Courthouse '| DOC #: 500 Pearl Street Il DATE rep. □□□□□□□ New York, New York 10007 DATE FILED: 1 ——————————_—_=_= Re: UA Local 13 Pension Fund, et al. v. Sealed Air Corp., et al., No. 19-10161 Dear Judge Stanton: We write on Sealed Air’s behalf in connection with Plaintiffs’ motion for class certification and appointment of class representatives and counsel filed on July 15, 2022. Dkt. 82. As anticipated at the conference before Your Honor on July 7, 2022, Plaintiffs’ motion was filed along with an expert report (by a PhD in economics) and supporting exhibits totaling nearly 200 pages, including three affidavits from would- be class representatives. Under the Local Rules, Defendants’ response is due on July 29, 2022. Plaintiffs’ motion raises several issues for which Sealed Air intends to present opposing expert testimony—particularly in light of the Supreme Court’s decision last year in the Goldman Sachs case. Goldman Sachs vy. Arkansas Teacher Ret. Sys.,

(2021). Goldman underscores the importance of taking a hard look—at the class certification stage—at the statements alleged to be misleading and their impact upon the price of the securities. Given its recent vintage, Goldman also means that care will be required in the preparation of responsive papers. In order to prepare and present evidence opposing Plaintiffs’ motion, including to have an adequate opportunity to depose Plaintiffs’ witnesses as to their affidavits and to prepare expert analyses, Sealed Air □□ respectfully requests a two-week extension—until August 12, 2022—1to submit its opposition brief and responsive expert testimony. We have conferred with Plaintiffs’ counsel, and they do not oppose this request, which is the first request for an extension of this deadline. □ Respectfully submitted, □□ /s/ Vincent Lev Vincent Levy