GISKAN SOLOTAROFF & ANDERSON LLP Attorneys at Law

HON. VALERIE FIGUEREDO UNITED STATES MAGISTRATE JUDGE Dated: October 23, 2025 VIA ECF The motion to seal is GRANTED. The □ Clerk of the Court is directed to maintain The Honorable Valerie Figueredo the viewing restrictions at ECF Nos. 27 Daniel Patrick Moynihan Courthouse and 28. The Clerk of the Court is 500 Pearl Street, Room 1660 respectfully directed to terminate the New York, NY 10007 motion at ECF No. 26. Re: Letter Motion to Seal — Melman vy. Daisy, Inc., 25 Civ_ 1725 (VF) Dear Judge Figueredo: We represent Plaintiff in the above-referenced case. As Your Honor may recall, Plaintiff brought individual claims for unlawful termination and unpaid overtime wages. The Parties have agreed to settle all claims, and, on September 22, 2025, the Parties submitted for Your Honor’s approval the proposed FLSA overtime wage settlement agreement (ECF No. 25). Pursuant to chambers’ instructions of October 10, 2025, the Parties respectfully request leave to file under seal (1) the confidential non-FLSA settlement agreement and (2) the related non-disclosure agreement.! The Parties respectfully request that the Viewing Level be set at “Selected Parties.” Both Parties consent to these documents being sealed and removed from the public docket because the confidentiality of the information contained therein forms an essential part of the bargained-for settlement terms. Very Truly Yours, Raymond Audain Raymond Audain

' Because the non-FLSA settlement agreement/NDA does not release wage hour claims, it is not subject to judicial approval. See Fleming v. Nadap, Inc.,

, at *4 (S.D.N.Y. Dec. 9, 2024).

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