public docket. With respect to Respondent's address, Petitioners' proposed redactions conform to Individual Rule 6, which states, infer alia, that home addresses can be partially redacted from court fil prior permission. Regarding Respondent's telephone number, while the document on which the nun ears is a judicial document to which a presumption of public access attaches, see, e.g., United States v. □□□□ F.3d 141, 145 (Qd Cir. 1995), "the Court finds this traditionally private information weighs heavily in balancing against the presumption of public access, see, e.g., United States v. Amodeo, 71 F.3d at 0-51, and otherwise has no bearing on the lawsuit, and therefore the public will not be prejudiced if denied acces information." Cantinieri v. Verisk Analytics, Inc., No. 21 Civ. 6911,

, at *4 (E.D.N.Y. Feb. (citing Cohen v. Gerson Lehrman Grp. Inc., No. 09 Civ. 4352,

, at *2 (S.D.N-Y. S 2011) ). Because Plaintiffs’ proposed redactions are sufficiently narrowly tailored and pertain to « private information, the application is GRANTED. of Court is respectfully directed to place ECF No. 5-1 under seal with access limited to the applicable par to keep ECF No. 11-1 under seal with access limited to the applicable parties. The Clerk of Court is also directed to terminate ECF No. 10. SO ORDERED. Dated: May 12, 2025 Le The Honorable Dale E. Ho New York, New York \ > United States District Judge Dale E. Ho Southern District of New York United States District Judge 40 Foley Square New York, NY 10007 Re: Banco Credit Suisse (Mexico), S.A. and Casa de Bolsa Credit Suisse (Mexico) S.A. de C.V. vs. Rafael Helguero Ruiz, Case No. 25-cv-03020 (DEH) [rel. Case No. 25-cv-01160 (DEH)] Letter Motion to Redact Respondent’s Personal Information Dear Judge Ho: We represent the Petitioners Banco Credit Suisse (Mexico), S.A. and Casa de Bolsa Credit Suisse (Mexico) S.A. de C.V. in this action. We write to request an Order from the Court that ECF Document 5-1, filed on April 11, 2025, be prospectively sealed to protect Respondent’s home address and telephone number from public view pursuant to Rule 6 of Your Honor’s Individual Rules and Practices in Civil Cases. ECF 5-1 is a copy of the Arbitration Award Petitioners seek to have confirmed in this action, attached as Exhibit A to the Splittgerber Declaration in support of the Petition to Confirm. Subject to the Court’s permission and any further instruction, we would then refile the Declaration in Support with a redacted copy of Exhibit A to replace current docket entry ECF No. 5-1. This request is made with Respondent’s consent and at his behest. The request to seal and redact is narrowly tailored, as it is designed only to protect Respondent’s presumptively sensitive personal information. The limited redaction will not impinge on the presumption of the public’s right to access judicial documents in this case.!

1 See, e.g., Dubose v. Suny Mar. Coll. Off. of Fin. Aid, No. 1:24-CV-05547 (JLB),

, at *2 (S.D.N.Y. Mar. 21, 2025) (ordering redaction of addresses and phone numbers “[b]ecause ‘[t]he public interest in [individual Epstein Becker & Green, P.C. | 875 Third Avenue | New York, NY 10022 | t 212.351.4500 | f 212.878.8600 | ebglaw.com

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Moreover, Respondent’s personal information is no longer in dispute or necessary for Your Honor’s determination of any issues in this case,2 as Respondent has now acknowledged service and his actual notice of this action, consented to electronic service of all process through his counsel in Mexico, waived any additional personal service pursuant to any international agreements that might apply, and stipulated that he does not oppose confirmation of the final arbitration Award (see ECF No. 9-1). Consistent with Rule 6.d.iii. of Your Honor’s Individual Rules and Practices in Civil Cases, Petitioners are (1) publicly filing on ECF this letter motion with an electronically-related copy of ECF No. 5-1 (Exhibit A to this letter motion) with the proposed redactions;3 and (2) filing it under seal on ECF, with the proposed redactions highlighted in the attached copy of ECF No. 5-1 (Exhibit A). Accordingly, Petitioners respectfully request that the Court approve the proposed redactions and order sealing of ECF 5-1. Respectfully submitted, EPSTEIN BECKER & GREEN, P.C. /s/ Scott J. Splittgerber Scott J. Splittgerber Attorneys for Banco Credit Suisse (Mexico), S.A. and Casa de Bolsa Credit Suisse (Mexico) S.A. de C.V. Cc: Rafael Helguero Ruiz contact information] is low and the privacy interest is high’”) (quoting In re SunEdison, Inc. Sec. Litig., No. 16-CV- 7917 (PKC),

, at *4 (S.D.N.Y. Sept. 25, 2019)). 2See Spencer-Smith v. Ehrlich, No. 23-CV-2652 (LJL),

, at *2 (S.D.N.Y. Apr. 15, 2025) (“Given that [the party’s address and personal phone] information has no relevance to the dispute at bar, and that such redactions would be narrowly-tailored, the Court finds that the privacy interests of the parties whose contact information is at issue outweigh the presumption of access.”); see also Cantinieri v. Verisk Analytics, Inc., No. 21CV6911NJCJMW,

, at *4 (E.D.N.Y. Feb. 23, 2024) (granting redaction of addresses and phone numbers; finding that a party’s and other individuals’ personal addresses and phone numbers were “traditionally private information” that “had no bearing on the lawsuit” and therefore the redactions would not prejudice the public’s right of access). 3 The only proposed redactions are on page 13 of Exhibit A (page 2 of the Final Award).