eniorcement Jurisdiction 1s a Judicial document. see Chron. books, LLU v. □□□□ Ine.,

, at *1 ($.D.N.Y. Feb. 12, 2020) (citing cases). However, | parties have identified countervailing factors that support the limited redactions that they request. See Mercer Health & Benefits LLC v. DiGregorio,

, at *1 (S.D.N.Y. July 13, 2018) (holding that understanding that settlement would remain confidential was not sufficient to permit sealing but <—— allowing for limited redactions “for which the parties can make a compelling WV TORRICELLA LAW showing of the need for confidentiality”). The parties are hereby put on notice th if there is a motion to enforce the settlement or the settlement otherwise become . relevant to some requested judicial action, the Court will revisit this order. Via ECF - February 18, 2025 February 19, 2025 SO ORDERED. □ « The Honorable Lewis J. Liman ae PIG □□□□□ Daniel Patrick Moynihan United States Courthouse ao ee. 500 Pearl Street New York, NY 10007 Re: Insured Advocacy Group, LLC v. Spartan Services Corp. Case No.: 1:23-cev-07212-LJL Letter Motion For Leave to File Redacted Settlement Agreement Dear Judge Liman: Pursuant to your Honor’s “Procedure for Sealed or Redacted Filings” the Plaintiff, Insured Advocacy Group, LLC (“Plaintiff’ or “IAG”), hereby moves for leave to file a redacted version of the Settlement Agreement referenced in the parties’ Amended Stipulation of Dismissal and Order of Dismissal (the “Settlement Agreement’). The Settlement Agreement, with the portions to be redacted highlighted in red, is being filed separately under seal. Plaintiff intends to file the Settlement Agreement only because the Settlement Agreement provides for this Court to retain jurisdiction to enforce its terms, and your Honor has advised that the Court cannot retain jurisdiction absent the filing of the Settlement Agreement. The redacted information consists of the monetary terms of the Settlement Agreement. Those terms are highlighted in red. Plaintiff respectfully submits that that information should be redacted because disclosure of that information may benefit Plaintiff's competitors in the factoring industry and harm Plaintiffs negotiating position in other litigation which is pending in this Court and elsewhere where the same or substantially similar substantive issues raised by the pleadings in this action are in dispute. Conversely, the public has no material interest in the detailed financial terms of the Settlement Agreement. Accordingly, Plaintiff respectfully requests that the Court permit Plaintiff to file the Settlement Agreement with the requested redactions. The undersigned understands that Defendant does not oppose the relief requested in this Motion. Should your Honor require any further information, please do not hesitate to contact the undersigned. Respectfully submitted, /s Maurice J. Baumgarten Maurice J. Baumgarten