ORIGINAL |uspc spxy [DOCUMENT ELECTRIC BakerHostetler 0C#.____,__. | DATE FILED: TES eraHostetler LLP a (} F ng i} (; RSE} 45 Rockefeller Plaza New York, NY 10111 EMO ENDORSED on T 212.589.4200 F 212.589.4201 July 9. 2025 www. bakerlaw.com Gregory A. Mersol VIA ECF sereielpelrioaresen The Honorable Louis L. Stanton ee adn bani United States District Court [email protected] Southern District of New York Tustin, Guilhye Daniel Patrick Moynihan U.S. Courthouse direct dial: 212.589.4607 500 Pearl Street [email protected] New York, NY 10007

Re: Tanya Taylor v. Matrix Absence Management, et al. Case No.: 1:25-CV-01134 Dear Judge Stanton:

Pursuant to the Court’s Individual Practices, Section 3, defendants, The Long Term Disability Income Plan for Employees of the Federal Reserve System (the “Plan”) and Matrix Absence Management, Inc. (‘“Matrix”) (collectively, “defendants”), hereby file this letter to request the Court’s approval to file the claims file/administrative record under seal. This is an action for benefits under a long-term disability plan (the “Plan”) for eligible employees of the Federal Reserve Banks and the Board of Governors. While the Plan may not be governed strictly by ERISA, the Plan models long-term disability plans under ERISA. Accordingly, there is a claims file containing all relevant documents related to plaintiffs claim for long-term disability benefits under the Plan, a claims procedure, administrative process, and Plan standard of review. While there is a presumption of public access to judicial documents, “court documents may be sealed if ‘specific, on the record findings are made demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest.’” Braxton v. City of New York,

, at *6 (S.D.N.Y. Dec. 7, 2021) (quoting Dunham v. City of New York, No. 11-CV-01223,

, at *1,n.1 (S.D.N.Y. Mar. 10, 2021)). “Courts in this circuit regularly allow medical records to be filed under seal, finding that parties have a strong privacy interest in their medical information.” Braxton, at *6 (quoting Spring v. Allegany-Limestone Cent. Sch, Dist., No. 14-CV-0476S,

, at *1 (W.D.N.Y. Sept. 14, 2021); see also Paravas v. Tran, No. 21-CV-807,

, at *1 (S.D.N.Y. Mar. 11, 2022) (noting plaintiff's medical records were “properly under seal”). Atlanta Chicago Cincinnati Cleveland Columbus Costa Mesa Dallas Denver Houston Los Angeles New York Orlando Philadelphia San Francisco Seattle Washington, DC Wilmington

The Honorable Louis L. Stanton July 9, 2025 Page 2

The claims file totals more than 2,500 pages and contains the entirety of plaintiff Tanya Taylor’s documents related to her claim for long-term disability benefits. The claims file contains sensitive and confidential information. Specifically, the claims file includes all the medical records Taylor provided as well as the clinical information that she submitted in support of her appeal to Matrix. In addition, the claims file frequently references plaintiffs personal identifiers, such as her date of birth and social security number, in her medical records. The claims file also contains communications between her, her counsel, and Matrix. Finally, Matrix’s detailed denial letters, which specify exactly how it reached its determination and the medical documentation that it relied upon, are also in the claims file. Accordingly, defendants respectfully request the Court’s permission to maintain the claims □ ates file/administrative record under seal to protect the privacy interests of plaintiff. Defendants filed □ the claims file/administrative record contemporaneously with this request. □□□□ Counsel for defendants conferred with plaintiff's counsel on July 7, 2025, regarding this request. Ay wn Plaintiff's counsel does not oppose this request. □□ | Respectfully submitted,

BAKER & HOSTETLER LLP /s/ Gregory V. Mersol Gregory V. Mersol Lauren T. Stuy Justin A. Guilfoyle