JIRAHMAN LEGA |] DOCUMENT —______—_—_+__\— |] ELECTRONICALLY FILED 43 WEST 43RD STREET, SUITEH nog gy, NEW YORK, NY 10036 TEL: +1.347.433.6139 DATE FILED: 12/11/2023 FAX: +1.212.954.5391 □□□ WWW.RAHMANLEGAL.COM December 8, 2023 VIA ECF Hon. Katharine H. Parker Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007 Re: Request to Seal and Redact Einhorn v. Renaissance Economic Development Corporation et al. Case No. 1:22-cv-08436-KHP Dear Judge Parker, I represent the Plaintiff in the above-stated action. On account of sensitive information discussed at the last conference pertaining to medical history, the Plaintiff respectfully asks the Court to seal the transcript. The Plaintiff also asks the Court to reissue the prior order with last sentence of the first paragraph redacted or partially redacted. (See Order dated December 7, 2023, ECF Doc. # 74.) Defendant Renaissance Economic Development Corporation consents to the requested sealing.

Respectfully submitted, /s/ Hashim Rahman _. cation granted in part and denied in part. will not permit sealing of the entire transcript, but will permit redaction of the sensitive information from When the transcript becomes available, a notice will appear on the docket indicating that the transcript i At that time, Plaintiff shall file a Notice of Intent to Request Redaction of the transcript, and separately sh directly with the transcriber to have the relevant sensitive information redacted. request that the Court redact its own Order is denied because no sensitive information about Plaintiff is in that Order. Rather, the Order speaks in general terms about a category of discovery that is not permitte not discuss whether and to what extent documents within that category exist. Accordingly, sealing is not warra with Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006) and its progeny. ORDERED: ae See if lf acs