—— □ Lah 2 LiF FOR D u CNUUA LIFFORD CHANCE US LLP 31 WEST 52ND STREET c H AN G E NEW YORK, NY 10019-6131 TEL +1 212 878 8000 FAX +1 212 878 8375 www .cliffordchance.com BY ECF Direct Dial: +1 212 878 8205 E-mail: [email protected] The Honorable Lo is L. Stanton November 11, 2022 United States Distrigt Judge United States Courthouse 500 Pearl Street New York, NY 10007 Re: Frontier Airlines, Inc. v. AMCK Aviation Holdings Ireland Limited et al., 20 Civ. 9713 (LLS) Your Honor: pe uc I write on behalf of Defendants in this matter, and pursuant to Section 3.B of Your Honor’s Individual Practices, to request permission to file certain papers under seal in support of Lew 5 A Defendants’ motion for summary judgment. □□ In the motion for summary judgment filed contemporaneously herewith, Defendants refer to □ various documents that Plaintiff Frontier Airlines, Inc. (“Frontier”) has designated □□□ “Confidential” or “Highly Confidential” under the Stipulated Protective Order dated January 4, 2022. This material includes: e Exhibit 7 to the Declaration of Paul Sheridan dated November 10, 2022; e Exhibits 1-19 and 22-26 to the Declaration of Jeff E. Butler dated November 11, 2022; and e Summaries of the foregoing in Defendants’ Memorandum of Law and Statement of Material Facts Pursuant to Local Civil Rule 56.1. Accordingly, Defendants are filing public redacted versions and under seal unredacted versions of these documents, as required by Section 8.4 of the Stipulated Protective Order. Defendants take no position as to whether there is a “most compelling reason” to seal these documents. See Lugosch v. Pyramid Co.,

(2d Cir. 2006). If Frontier wishes to keep the above information under seal, Defendants would have no objection to such an application by Frontier. Respectfully submitted, oa ~ s/ Jeff E. Butler [eso SDNY DOCUMENT f E. Butl Jeff E. Butler bp a he TRE. □□□□ Wiiok Bo | pate Fit: (2lyla~e —