USDC SDNY DOCUMENT L E E D Ss B R O WN L ELECTRONICALLY FILED L DOC #: One Old Country Road, Ste.?|f DATE FILED: 10/21/2025 Carle Place, NY 11514 (516) 873-9550 Attorneys at Law

October 20, 2025

Honorable Judge Analisa Torres Southern District of New York 500 Pearl Street New York, New York 10007 Re: Batanjany et al. v. Clear Street Management LLC, et al. Docket No. 25-cv-08420 Your Honor: This office represents Defendants Clear Street Management LLC, Clear Street Derivatives LLC, Clear Street LLC, Clear Street Holdings LLC, Clear Street Group Inc., Uriel Ephraim Cohen, and Kenneth Ari Sicklick. We write to advise the Court that Defendants are filing the following documents: (1) a Notice of Motion to Compel Arbitration (2) a Memorandum of Law in Support of the Motion to Compel Arbitration (3) a Memorandum of Law in Opposition to Plaintiffs’ Motion for Injunctive Relief (4) the Declaration of Andrew Volz submitted in support of the Motion to Compel Arbitration and in opposition to Plaintiffs’ motion. Defendants respectfully request that this Court stay further briefing on Plaintiffs’ injunction motion pending resolution of the Motion to Compel Arbitration. Plaintiffs’ reply papers are presently due October 24, 2025. Because Plaintiffs expressly agreed to arbitrate all employment- related disputes, this case should not proceed further in court. Allowing additional briefing would risk further public dissemination of immaterial and inflammatory material in a forum that is not the proper venue for these disputes, and would unnecessarily burden the Court and the parties, while the threshold arbitrability issue is pending. This is the first request for such relief. Accordingly, Defendants ask the Court to stay the briefing on the injunction motion until the Court resolves the Motion to Compel Arbitration. In the alternative, Defendants request any such other relief as the Court deems appropriate to prevent unnecessary filings before the arbitrability determination.

Defendants contacted Plaintiffs’ counsel seeking their consent to this request, but they declined to consent unless Defendants agreed to the entry of a temporary restraining order. Defendants cannot agree to that condition. Plaintiffs remain free to seek interim or injunctive relief in arbitration, as both JAMS and AAA rules expressly permit same. (AAA Commercial Rule R- 39; JAMS Employment Arbitration Rule 24(e).) We thank the Court for its attention to this matter.

Very truly yours, LEEDS BROWN LAW, P.C. fick: Otlieve RICK OSTROVE cc: Opposing Counsel (via ECF)

The motion to stay further briefing on Plaintiffs' motion for a preliminary injunction is DENIED. Even if the "dispute is to be arbitrated," that "does not absolve the court of its obligation to consider the merits of a requested preliminary injunction." Roso-Lino Bev. Distributors, Inc. v. Coca-Cola Bottling Co. of New York, Inc.,

(2d Cir. 1984) (per curiam); see also Thales Avionics, Inc. v. L3 Techs., Inc.,

(S.D.N.Y. 2024).

SO ORDERED. □□□ ee vork ~~ ANALISA TORRES ° United States District Judge