El PRYOR CASHMAN LLP New York | Los Angeles | Miami 7 Times Square, New York, NY 10036-6569 Tel: 212-421-4100 Fax: 212-326-0806 pryorcashman.com Maxwell Breed Direct Tel: (212) 326-0113 [email protected]

August 22, 2025 The motion is granted for the reasons provided by counsel. The Clerk of Court is respectfully VIA ECF directed to seal Dkt. Nos. 658-8, 658-11, 658-12, and 658-16, and close Dkt. Nos. 673 and 691. Hon. Lewis L. Liman United States District Court sO eng fe Southern District of New York eae UE Rais . . . . a afl. fe Daniel Patrick Moynihan United States —- “TUS yikes a Courthouse United States District Judge 500 Pearl Street A 5. 2025 New York, NY 10007 ugust 2), Re: | Supplemental Letter in Support of Motion to Seal—Lively v. Wayfarer Studios LLC et al., No. 1:24-cv-10049-LJL Dear Judge Liman: On behalf of nonparties Katherine Case and Breanna Butler Koslow, we write, in accordance with your Honor’s instruction (Dkt. 680), to particularize grounds for sealing and redacting portions of four exhibits (Dkts. 554-19, 554-22, 554-23, and 554-30) to plaintiff Blake Lively’s Omnibus Motion to Compel (Dkt. 553).! We respectfully submit that the narrow redactions are necessary to protect both confidential business relationships and the privacy and reputational interests of nonparties. Consistent with the Second Circuit’s framework in Lugosch v. Pyramid Co. of Onondaga, F.3d 110 (2d Cir. 2006), the first determination is whether the material sought to be sealed qualifies as a “judicial document.” Where, as here, excerpts of messages are irrelevant to the Court’s adjudicative function, no presumption of access attaches. Courts have confirmed that discovery materials retain their non-judicial character even when filed in discovery motions. E.g., Authors Guild vy. OpenAl Inc., No. 23-CV-10211 (SHS) (OTW),

, at *2 (S.D.N.Y. Jan. 10, 2025) (holding that the non-judicial character of discovery materials is not altered by a court’s review of those materials in discovery motions). And even if a limited presumption applied, it is overcome by strong privacy interests. See Al Thani v. Hanke, No. 20-CV-4765 (JPC

, at *1 (S.D.N.Y. Jan. 15, 2021) (granting request to redact names because “the privacy interests of [defendants’] . . . investors, who are not parties to this case and whose identities are not relevant to the resolution of the motions... , outweigh the presumption of public access”’). In line with this precedent, our narrowly tailored redactions—limited to nonparty TAG clients and

' The Court has previously approved and applied redactions limited to the personal identifying information of conversation participants. We do not address those redactions in this submission.

li PRYOR CASHMAN LLP

Hon. Lewis L. Liman August 22, 2025 Page 2 discussions irrelevant to the specific facts of this case—fall outside the presumption and are properly withheld to protect confidentiality and privacy. Each proposed redaction involves nonresponsive communications of Ms. Case and Ms. Butler Koslow about private crisis management work for nonparty clients of defendant The Agency Group PR LLC. The redacted portions do not bear on the issues raised by Ms. Lively’s motion and do not relate to her (or any other parties’) claims. The redacted portions are not relevant to the adjudicative process and carry, at most, a weak presumption of access. Each proposed redaction is treated below, referring to the nonparties generically. Exhibit 19 (BBKOSLOW-000001684):

The redaction covers messages about strategic considerations and responsive measures for a nonparty TAG client. These communications include confidential BBKOSLOW- client relationships and private business affairs unrelated to 1 000001687 his action and are Confidential under the Protective Order. Exhibit 22 (BBKOSLOW-000004640): No Bates_~ DSeiption The redaction covers a message about a nonparty TAG client, together with strategic considerations. The content involves confidential client relationships and private BBKOSLOW- business matters unrelated to this proceeding and should be 000004642 sealed as Confidential under the Protective Order. The redactions cover messages addressing news coverage and articles about a nonparty TAG client. The information implicates client relationships and communications of a BBKOSLOW- personal nature unrelated to this litigation and should B—4 000004643 remain Confidential under the Protective Order. Exhibit 23 (KCASE-000004949): No Bates DSeiption The redactions cover messages about a nonparty TAG client, and strategic public-relations work, including strategy discussions, media monitoring activities, and a oice note with identifying information. Continued disclosure would air nonpublic client relationships, confidential business plans, and sensitive communications KCASE- nrelated to this matter, all of which are designated S—8 000004951 Confidential under the Protective Order.

li PRYOR CASHMAN LLP

Hon. Lewis L. Liman August 22, 2025 Page 3 Exhibit 30 (BBKOSLOW-000008602): No. [Bates Description, The redactions cover messages providing a status update about ork performed for a nonparty TAG client. This nonpublic client BBKOSLOW- relationship is sensitive, unrelated to this litigation, and 000008603 Confidential under the Protective Order. The redactions cover messages about a nonparty TAG client, ogether with strategic considerations and responses. The content involves confidential client relationships and private business BBKOSLOW- matters unrelated to this proceeding and should be sealed as 10 000008603 Confidential under the Protective Order. The redactions cover messages about media monitoring and strategy for anonparty TAG client. These communications BBKOSLOW- include confidential client relationships and strategy unrelated to 11-12 {000008606 his litigation and are Confidential under the Protective Order. The redactions cover messages about media monitoring and strategy for a nonparty TAG client. These communications BBKOSLOW- include confidential client relationships and strategy unrelated to 13 000008606 his litigation and are Confidential under the Protective Order. The redactions cover messages about nonparty TAG clients, as ell as discussions regarding strategy, coordination, and planning BBKOSLOW- for those client engagements. The information reflects nonpublic 000008607— client relationships and sensitive business communications BBKOSLOW- nrelated to the action and should remain Confidential under the 14—29 000008609 Protective Order. The redaction covers a message transmitting a link about a Inonparty TAG client. Continuing disclosure would air confidential client relationships and personal identifiers unrelated BBKOSLOW- o the litigation, warranting Confidential treatment under the 30 000008609 Protective Order. We thus respectfully request that the Court seal the specified portions of Exhibits 19, 22— 23, and 30. Respectfully,

Maxwell Breed ce. All Counsel (by ECF)