Marsh USA LLC v. Parrish

G RSON DU N N Harris M. Mufson Partner T: #1 212.351.3805 M: +1 917.922.1740 July 30, 2025 [email protected] VIA ECF _ SO ORDERED: Hon. George B. Daniels B Dav United States District Court 4 2. Wwe □ Southern District of New York Ggorge B, Daniels, U.S.DJ.

500 Peari St ‘ New York, NY 10007-1312 pated: YUL 3 9 2025 Re: Marsh USA LLC v. Parrish et al., Case No. 25-cv-6208 □ Letter-Motion to Redact Exhibits to Declarations in Support of Motion for Temporary Restraining Order Dear Judge Daniels: We represent Plaintiff Marsh USA LLC in the above-referenced action. Pursuant to Your Honer’s individual Rules and Practices, Section 1.D, Marsh respectfully seeks leave to redaci and file as redacted discrete portions of certain exhibits attached to declarations in support of Marsh’s Motion for Temporary Restraining Order and Preliminary [njunction.

Marsh seeks to redact the personal email addresses and personal ceil phone numbers of individual non-parties, as well as information about the compensation offered to them by Hawden US Services, LLC, a direct competitor of Marsh. These individuals’ privacy interests in such sensitive and private information weigh heavily against the presumption of public access in a court's balancing equation. Courts regularly allow the narrow redaction of identifying and private information of non-parties, as this information enjoys only a weak presumption of public access. □ See Eckhart v. Fox News Network, LLC, No. 20-cv-5593, 2024 WL 4931857, at*3 (S.D.N.Y. Dec. 2, 2024} (“[T]he personal email addresses and phone numbers of various non-parties are eniitled to continued sealing. There is only a weak presumption of public access for irrelevant information of that sort, and courts routinely permit such redactions to protect the privacy of non-parties.”).

The limited redactions submitted are narrowly tailored to protect the privacy interests of non-parties. These redactions do not obfuscate or otherwise misrepresent the content of the exhibits, nor do they go so far as to anonymize the identities of the non-parties. Rather, they conceal only specific personal identifying information which will not directly affect the adjudication of Marsh's claims.‘ Accordingly, Marsh respectfully requests that the Court grant this letter-motion.

1 Marsh has separately redacted proprietary compensation information, consistent with Your Honor's Individual Rules and Practices, Rule Section 1.D(i).