Loh Xiao Han v. Interexchange, Inc.

LEW 1) ww JUTIOS Lewis Johs Avallone Aviles, LLP Counsellors at Law December 13, 2024 VIA ECFHonorable Jennifer L. Rochon, U.S.D.J.

United States District Court Southern District of New York Pearl Street New York, New York 10007 Re: Celine Loh Xiao Han, et al. v. InterExchange, Inc. et al., Case No. 23-cv-7786 (JLR) Dear Judge Rochon: We are counsel for the Plaintiffs in the above-captioned action. We write pursuant to your Honor’s Individual Part Rules, the Court’s Standing Order, 19-MC-00583, and Section 6 of the Southern District’s ECF Rules & Instructions, to respectfully request that the Court permit certain documents to be submitted under seal in connection with the motion to be relieved as counsel that was filed by Plaintiffs on December 2, 2024 (Dkt.83) and scheduled for a hearing on December 17, 2024.

The documents at issue are communications directed to counsel from Plaintiff Samantha Carolina Molina Espinoza in response to her receipt of the above referenced motion papers, which are privileged attorney-client communications, but which we believe should be provided to Your Honor in considering the pending motion. Pursuant to your Honor’s Individual Practice Rules, Plaintiffs have conferred with counsel for Defendant InterExchange (“IEx”) and for the Eiffel Defendants regarding the intention to have the correspondence filed under seal. The Eiffel Defendants and Defendant IEx communicated that they do not waive any objections to the submission and expressly reserve all rights.”

The correspondence does not change the nature of the relief sought by Plaintiffs’ counsel.

Respectfully submitted, . < Plaintiffs’ request to file counsel's correspondence with Plaintiff Yttechen (elP ange Samantha Carolina Molina Espinoza, Dkt. 92, under seal is . GRANTED. The correspondence implicates the attorney-client Michael J. Del Piano : . . privilege, which outweighs the presumption of access that mjdelpiano @ lewisjohs.com ee Islandia Office otherwise ordinarily attaches to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (3d MJD/Ic □ Cir. 2006). : AIC 1 via ECF ve onnsen wae Dated: December 16, 2024 SO ORDERED.

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