Edgewood Partners Insurance Center v. PPD Development, L.P.

: 1140 Avenue of the Americas, 17th Floor, New York, NY □□□□□ b | Shapiro Arato Bach Lp shone: □□□□□□□□□□□ www.shapiroarato.cor Julian S. Broc [email protected] Direct: 212-257-4885 August 22, 2025 VIA ECF Hon. Valerie Figueredo United States District Court Southern District of New York Pearl Street New York, NY 10007 Re: Edgewood Partners Ins. Ctr. Inc. v. PPD Development, L.P., No. 1:22-cv-06957 Dear Judge Figueredo: Defendant PPD Development, L.P., (“PPD”) respectfully seeks leave to file under seal or with redactions portions of its submissions in opposition to EPIC’s Motion for Reconsideration.

In particular, PPD seeks to redact portions of its Memorandum in Opposition to Plaintiff's Motion for Reconsideration and to file under seal Exhibits A, D, E, and F of the Declaration of Julian Brod dated August 22, 2025.

The materials that PPD seeks to redact or file under seal include text of the confidential 2019 EPIC/PPD consulting agreement or describe the substance of that agreement or contain information regarding the amount of consulting fees owed or claimed to be owed under that agreement. Exhibits A, D, E, and F to the Brod Declaration are designated Confidential under the protective order at ECF 75. This Court has previously granted similar requests to seal. See, e.g., ECF 32, 50, 79, 109.

Accordingly, PPD respectfully seeks leave to file under seal and/or with redactions the above referenced materials.

\ | \) 1) SAL A . Respectfully submitted, HON, VALEREFIGUEREDO .

UNITED STATES MAGISTRATE JUDGE San $ Brod Dated: 8/25/25 wlan. PTO motion to seal the memorandum of law is GRANTED.

Clerk of Court is directed to maintain the viewing at ECF No. 113. With regards to the exhibits at No. 114, the materials are provisionally sealed. PPD is to move to permanently seal the documents and a showing under Lugosch v. Pyramid Co. of 435 F.3d 110 (2d Cir. 2006) by September 29, to justify sealing the subject documents in their