] USDC SDNY Barnes & Barnes, P.C. | DOCUMENT Attorneys at Law ELECTRONICALLY FILED DOCA DATE FILED:__5/3/2023

March 13, 2023 VIA ECE Honorable Stewart D. Aaron United States District Court Magistrate Judge Southern District of New York 500 Pearl Street, Room 1970 New York, New York 10007 Re: Cesfin Ventures LLC v. Al Ghaith Holding Company, et al., 1:21-cv-01395(PGG)(SDA) Dear Judge Aaron: This firm represents Respondent-Defendant Six Star Representation of Companies LLC (“Six Star”) in the above-referenced action. We write in accordance Section HI(E) of Your Honor’s Individual Practices to request permission to file under seal an ex parte application to withdraw as Six Star’s counsel of record pursuant to Rule 1.4 of the Local Rules of the United States District Courts for the Southern and Eastern Districts of New York (“Rule 1.4”) and to provide Six Star at least thirty (30) days to retain new counsel. Rule 1.4 provides: An attorney who has appeared as attorney of record for a party may be relieved or displaced only by order of the Court and may not withdraw from a case without leave of the Court granted by order. Such an order may be granted only upon a showing by affidavit or otherwise of satisfactory reasons for withdrawal or displacement and the posture of the case, including its position, if any, on the calendar, and whether or not the attorney is asserting a retaining or charging lien. All applications to withdraw must be served upon the client and (unless excused by the Court) upon all other parties. Courts in this District and in the Eastern District routinely grant requests to file applications for withdrawal on sealed ex parte basis. See, e.g., Hampshire Grp. Ltd. v. Scott James Co., L.L.C., No. 14 Civ. 2637 (JGK)(MHD),

, at *3 n.3 (S.D.N.Y. July 27, 2015) (sealing of letters and time sheets as part of an application to withdraw “wholly appropriate”); Callaway Golf Co. v. Corp. Trade Inc., No. 10 CIV. 1676 (GBD)(JCF),

, at *5 (S.D.N.Y. July 6, 2011) (“Documents in support of motions to withdraw as counsel are routinely filed under seal where necessary to preserve the confidentiality of the attorney-client relationship between a

party and its counsel, and this method is viewed favorably by the courts”) quoting Team Obsolete Ltd. v. A.H.R.M.A. Ltd.,

(E.D.N.Y. 2006). See also Rule 1.4 Cmt. Note (Rule 1.4 provisions do not “preclude the Court from permitting the reasons for withdrawal to be stated in camera and under seal in an appropriate case.”) Our submission will not address the merits of this case, but will contain privileged and confidential information concerning the factual reasons which necessitate counsel’s withdrawal. Thank you. Respectfully submitted, “SSS Leo K. Barnes, Jr. ce: All counsel of record via ECF Six Star Representation of Companies LLC via email

Application GRANTED. For the reasons set forth herein, the Court finds that the request to seal is appropriate to preserve the confidentiality of the attorney-client relationship. For the same reason, the separate motion to seal by counsel for the Ghaiths (see ECF No. 152-4, at 2-3 (addressing motion to seal)) is granted. SO ORDERED. Dated: May 3, 2023 ) > 4 2