SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP ONE MANHATTAN WEST NEW YORK NY 1OO0I FIRM/APFILIATE OFFICES _ BOSTON TEL: (212) 735-3000 □□□□□□□ FAX: (2 [ 2) 735-2000 LOS ANGELES PALO ALTO WWW, SKADDEN.COM WASHINGTON, D.C. SSe0 mmr DIRECT FAX BEIJING S17-777-3529 BRUSSELS EMAIL ADDRESS. □□ □□□□□ [email protected] □□ □□□□□ MUNICH □ □□□□□ August 23, 2024 □□□ □□□□ SHANGHAI SINGAPORE □□□□□ TORONTO VIA ECF Su L Honorable Denise L. Cote ste } United States District Court Ky Southern District of New York | eee 500 Pearl Street, Room 1910 Pda] 4 New York, NY 10007 RE: Kelly-Starkebaum v. Papaya Gaming, Ltd. et al., No, 1:24-cv- 02310-DLC Dear Judge Cote: On behalf of Defendants Papaya Gaming, Ltd. and Papaya Gaming, Inc, (together, “Papaya”), and pursuant to Rule 8.B of Your Honor’s Individual Practices in Civil Cases, we respectfully submit this letter motion to request that certain portions of the Declaration of Mika Palevsky in Support of Defendants’ Motion to Compel Arbitration (the “Declaration’”) be filed under seal. Specifically, Papaya seeks to file under seal certain personal information about Plaintiff including Plaintiff's email address and financial information associated with Plaintiff's Papaya mobile gaming accounts. Consistent with Your Honor’s Individual Practices, Papaya is contemporaneously filing (i) a publicly available, redacted version of the Declaration, and (ii) unredacted version of the Declaration under seal. Papaya ultimately defers to Plaintiff regarding the necessity or desirability of filing under seal, but is making this letter request solely in an abundance of caution to protect any concerns about public disclosure that Plaintiff may have. Papaya reserves all rights with respect to future submissions. Papaya notes that this Court has allowed the filing of documents with personal information such as email addresses in redacted form in order to protect privacy interests. See e.g., Anderson v. N.Y.C. Health & Hosps, Corp., No. 16-CV-

1051 (GBD) (KHP),

at *3 (S.D.N.Y. Mar. 4, 2020) (“[T]he Court appreciates that there is certain information . . . such as the applicants’ home addresses, personal phone numbers, and email addresses, that is not public . . . [and] has been recognized by courts in this Circuit as the type of personal information that should be shielded from public disclosure.”); Cohen v. Gerson Lehrman Grp., Inc., No. 09 Civ. 4352(PKC),

, at *2 (S.D.N.Y. Sept. 15, 2011) (allowing redactions of individual contact information, such as email addresses, because “[s]uch information is not at issue in this dispute and the individuals have a countervailing privacy interest in their non-disclosure”).

Respectfully submitted, is! Michael W. McTigue Jr.

ce: All counsel of record (by ECF)