DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: DATE FILED: 10/6/2025 ALEXANDRA POOLOS, Plaintiff, ORDER -V- 23-CV-8896 (GHW) (HJR) PARAMOUNT GLOBAL, ET AL., Defendants.

HENRY J. RICARDO, United States Magistrate Judge. Before the Court are three Letter Motions requesting leave to file certain documents under seal or with redactions. See ECF Nos. 216, 229, 238. Neither party objects to these requests. After reviewing the proposed redactions to the relevant submissions, the Court concludes that Plaintiff's proposed redactions to the documents filed at ECF Nos. 231-32 are sufficiently tailored to justify redactions and are otherwise consistent with the presumption in favor of public access to judicial documents under Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006) (outlining the standard for overcoming the presumption in favor of public access). Accordingly, Plaintiff's redactions to the documents at ECF Nos. 231-32 are approved. Additionally, Exhibit C to the Declaration of Lisa E. Dayan in support of Defendants’ objections filed under seal at ECF No. 221-3 is properly filed under seal and is approved.

However, the Court concludes that the proposed sealing of or redactions to certain documents filed at ECF Nos. 218–19, 221-1, 221-2, 232–33, and 239–40 are not sufficiently tailored to justify redactions in light of the presumption in favor of

public access to judicial documents under Lugosch.1 With respect to the memorandum of law in support of Defendants’ objections filed at ECF Nos. 218–19, the redactions at pages 7 (first redaction), 13 (second and third redactions), 18, 19 (top half of page and footnote 9), 22 (first redaction), and 23 are approved as sufficiently tailored and the proposed redactions at pages 6, 7 (second redaction), 8–10, 12, 13 (first redaction), 19 (bottom half of page), 20–21, and 22 (second redaction) are rejected as overly broad. Defendants are directed to

file an amended version of this document with the rejected redactions removed. With respect to Exhibit A to the Declaration of Lisa E. Dayan in support of Defendants’ objections filed under seal at ECF No. 221-1, the proposed sealing is rejected as overly broad. The exhibit was already filed with approved redactions at ECF No. 208 and there is no reason that it should be filed under seal this time. With respect to Exhibit B to the Declaration of Lisa E. Dayan in support of

Defendants’ objections filed under seal at ECF No. 221-2, the proposed sealing is rejected as overly broad. Defendants are directed to file an amended version of this document in redacted form, with no redactions to the following sections of the report on pages 1–2 (Background and Qualifications, Purpose of Evaluation, and Subject Matter of Expected Testimony), 3 (Sources of Information), and 39–40 (Statement of

1 The page numbers cited herein refer to the PDF page numbers of the PDFs emailed to Chambers with the proposed redactions highlighted. Compensation, Depositions and Trials: Last Four Years, and Publications: Last Ten Years). With respect to Plaintiffs memorandum of law in opposition to Defendants’ objections filed at ECF Nos. 232-33, the proposed redactions to pages 12 and 20-22 are approved as sufficiently tailored, and the proposed redactions to pages 9 and 29 are rejected as overly broad. Plaintiff is directed to file an amended version of this submission with the rejected redactions removed. With respect to the reply memorandum of law in support of Defendants’ objections filed at ECF Nos. 239—40, the proposed redactions to pages 6—7 and 10 are approved as sufficiently tailored, and the proposed redactions to pages 5, 8, 11, and 14 are rejected as overly broad. Defendants are directed to file an amended version of this submission with the rejected redactions removed. Accordingly, the Letter Motions at ECF Nos. 216, 229, and 238 are each GRANTED IN PART and DENIED IN PART. The parties are directed to file the amended documents that reflect only the approved redactions on the public docket by October 14, 2025. The Clerk of Court is respectfully directed to terminate the Letter Motions at ECF Nos. 216, 229, and 238 as GRANTED IN PART and DENIED IN PART. SO ORDERED. Dated: October 6, 2025 CLL New York, New York He J. Ricar United States Nfagistrate Judge