WALTER J. LACK LAW OFFICES ALEXANDRA J. NEWSOM STEVEN C. SHUMAN ANDREW M. JACOBSON DANIEL G. WHALEN ENGSTROM, LIPSCOMB & LACK CHRISTOPHER A, KANNE BRIAN J. HEFFERNAN BRITTAN N. CORTNEY BRIAN LEINBACH A PROFESSIONAL CORPORATION DANIEL C WHALEN ANN A. HOWITT RACHEL M. LANNEN STEVEN J. LIPSCOMB 11601 WILSHIRE BOULEVARD, 14™ FLOOR SYDNEY M. DESMAN DAVID R. LIRA JASON L. TILLMAN GREGORY P. WATERS LOS ANGELES, CALIFORNIA 90025 PAUL W. ENGSTROM (1941 — 2010) ROBERT J. WOLFE (1961 — 2015) TELEPHONE 310-552-3800 FACSIMILE 310-552-9434

September 29, 2025 VIA ECF Hon. Paul G. Gardephe, U.S.D.J. United States District Court Southern District of New York Thurgood Marshall U.S. Courthouse 40 Foley Square, Court Room 705 New York, New York 10007

Re: Brink's Global Services USA, Inc. v. Bonita Pearl, Inc., et al., Case No.: 1:22-CV-06653-PGG REQUEST TO SEAL

Dear Judge Gardephe: I, together with my co-counsel, represent the Defendants in the above-referenced litigation. On August 14, 2025, Brink’s Global Services USA, Inc. (“Brinks”) served its Notice of Motion for Motion for Summary Judgment on Defendants’ Counterclaim and supporting documents and Defendants served their Opposition and responses on September 15, 2025. Defendants request that the Court allow redaction and sealing of certain portions of exhibits to Plaintiff's Opposition to Brink’s Motion for Summary Judgment. These documents are Exhibits 2 and 3, respectively, to the Declaration of Steven C. Shuman and are as follows: (1) the entire Confidential Settlement Agreement and General Release between Arat Jewelry Corp. et al., and Brink’s Global Services USA, Inc., and, (2) excerpted portions of the Deposition of Gloria Corrales that are already deemed confidential. Respectfully submitted, /s/ Steven C. Shuman SCS:mf #479286 cc: Gerald L. Kroll, Esq. Robert R. Viducich, Esq.

MEMO ENDORSED: As explained in this Court’s Individual Rules of Practice, “the parties’ consent or the fact that information 1s subject to a confidentiality agreement between litigants is not, by itself, a valid basis to overcome the presumption in favor of public access to judicial documents.” Indiv. R. of Prac. II.B (citing In re Gen. Motors LLC Ignition Switch Litig., No. 14- MD-2543(JMF),

, at *4 (S.D.N.Y. Aug. 11, 2015)). Moreover, “Ts|lettlement agreements submitted to the court in connection with a motion are unquestionably . . . judicial document[s]” to which “there is a presumption of [public] access” and “[t]he mere fact that [a] Settlement Agreement, signed by the parties, contains a confidentiality clause does not in and of itself constitute a countervailing consideration sufficient to overcome the presumption of public access[.]” Posada v. E. Coast Cap., No. 23-CV-01579 (RER) (JMW),

, at *2-3 (E.D.N.Y. Nov. 8, 2024). Because Defendants have articulated no basis for sealing beyond the parties’ agreement regarding confidentiality, the motion to seal is denied. Defendants are directed to publicly file unredacted versions of Exhibits 2 and 3 to the Declaration of Steven C. Schuman. The Clerk of Court is directed to terminate the motion (Dkt. No. 316). SO ORDERED. gh Paul G. Gardephe United States District Judge Dated: September 30, 2025