DENIED. These reasons all pertain to whether defendant should have ac to the materials, which is already the subject of the Court's or UNITED STATES DISTRICT COURT at Dkt. 28. None of these reasons are relevant as to why the presumption in favor of public access to judicial documents is SOUTHERN DISTRICT OF NEW YORK outweighed here. See Lugosch v. Pyramid Co.,

, (2d Clr. 2006). Satyanarayan Hegde, M.D., woe The Clerk of Court is respectfully directed to terminate the m: Plaintiff, Pro Se at ECF No. 26. V. Montefiore Medical Center, et al., SO ORDERED. Defendants. □ | | Case No. 1:25-cv-04222 (AS) Arun Subramanian, U.S.D.J. September 5, 2025 Date: September 15, 2025 LETTER-MOTION TO FILE EXHIBITS H-K UNDER SEAL (To The Honorable Judge Arun Subramanian) Dear Judge Subramanian: Pursuant to Local Civil Rule 7.1(d) and the Court’s Individual Practices, Plaintiff respectfully requests leave to file Exhibits H, I, J, and K to his Opposition to Defendants’ Motion to Dismiss under seal, while concurrently filing appropriately redacted versions for the public docket. Basis for Request 1. Nature of Exhibits: Exhibits H-K consist of Montefiore’s codified physician recruitment and credentialing materials, including its formal application process, terms and conditions, and structured screening questions. 2. Risk of Spoliation of Non-Codified Practices: While these materials are codified, they coexist with non-codified practices and unwritten procedures that are highly relevant to Plaintiff’s claims. Public filing of the full codified exhibits at this stage creates a risk that Defendants may retroactively alter or conform non-codified practices to the written policies in order to minimize liability, impairing the integrity of evidence. 3. No Prejudice to Defendants: Because the exhibits originate from Montefiore’s own systems, Defendants are already in possession of them or should be. Sealing causes no prejudice, but protects against unfair evidentiary manipulation. 4. Narrow Tailoring: Plaintiff is not seeking wholesale sealing. Redacted versions of Exhibits H-K are being filed publicly to maintain transparency. Sealing is requested

only for the complete, unredacted versions to ensure that the Court has access to the full materials without risk of spoliation. 5. Legal Standard: Under Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006), documents may be sealed when necessary to preserve higher values and where the request is narrowly tailored. Here, sealing is essential to preserve the integrity of non-codified evidence and Plainti(’s ability to prove his claims. Relief Requested Plainti( respectfully requests that the Court: 1. Permit Exhibits H–K to be filed under seal, with redacted versions available on the public docket; and 2. Grant such further relief as the Court deems just and proper. Respectfully submitted,

/s/ Satyanarayan Hegde _________________________ Satyanarayan Hegde, M.D. Plainti(, Pro Se 658 NW 120th Terrace, Apt. 6-325 Gainesville, FL 32607 Tel: (501) 425-2950 Email: [email protected]

CERTIFICATE OF SERVICE I hereby certify that on September 5, 2025, I served a true and correct copy of the foregoing PlaintiY’s Letter-Motion to File Exhibits H–K Under Seal and the attached proposed order on counsel for Defendant Montefiore Medical Center by electronic mail, addressed as follows: Jean L. Schmidt, Esq. Littler Mendelson, P.C. [email protected] Counsel for Defendant Montefiore Medical Center Dated: September 5, 2025 Gainesville, Florida

/s/ Satyanarayan Hegde ________________________ Satyanarayan Hegde, M.D. Plainti(, Pro Se 658 NW 120th Terrace, Apt. 6-325 Gainesville, FL 32607 Tel: (501) 425-2950 Email: [email protected]