MAYER |BROWN Mayer Brown LLP 1221 Avenue of the Americas Application GRANTED temporarily. That said, mere agreement eT □□□ between the parties to keep a document confidential is not 1: #1212 506 2500 . ‘er oe 09 t+ sufficient to keep a “judicial document” sealed or redacted. See, F. +1 212 262 1910 e.g., United States v. Wells Fargo Bank N.A., No. 12-CV-7527 www-mayerbrown.com March 27, 2023 (JMF),

, at *4 (S.D.N.Y. June 30, 2015) (citing cases). Thus, if Applied Bolting believes that the materials at Jonathan W. Thomas . . T: +1 212 506 2226 issue should remain sealed or redacted, it shall file a letter brief, F: +1 212 849 5895 within three days and not to exceed three pages, showing why [email protected] doing so is consistent with the presumption in favor of public access to judicial documents. See generally Lugosch v. Pyramid Via ECF Co. of Onondaga,

(2d Cir. 2006). The Honorable Jesse M. Furman United States District Judge The os of Court is directed to terminate ECF Southern District of New York N°: 44. SQ ORDERED 40 Centre Street, Room 2202 New York, New York 10007 (212) 805-0282 8.2023 Re: Applied Bolting Technology Products, LLC v. TurnaSure LLC: 1:22-cv-10506 (JMF) Dear Judge Furman: We write on behalf of Defendant and Counterclaim-Plaintiff TurnaSure LLC (“TurnaSure”). Pursuant to Section 6 of the Southern District of New York’s Electronic Case Filing Rules and Instructions, Section 7 of Your Honor’s Individual Rules and Practices in Civil Cases, and Standing Order 19-MC-00583, TurnaSure seeks permission to file its Opposition to Plaintiff and Counterclaim-Defendant Applied Bolting Technology Products, LLC’s Motion for a Temporary Restraining Order and Preliminary Injunction (“Opposition”) under seal. Pursuant to the Protective Order entered in this case (ECF No. 35), TurnaSure is contemporaneously filing a public redacted version of the Opposition. The reason for this request is that certain references contained in the Opposition, and exhibits appended to the Opposition contain materials produced in this litigation by Plaintiff and Counterclaim-Defendant Applied Bolting Technology Products, LLC under confidentiality designations pursuant to the Protective Order. TurnaSure takes no position with respect to whether those materials actually are confidential or warrant their designations. Respectfully submitted, {pom W. home Jonathan W. Thomas

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