anrorda i Sanford Heisler e isler Sharp McKnight, LLP State Street, 37th Fl harp New York, NY 10004 er . Telephone: (646) 402-56 cKnight Faxi(646) 402-681 www.sanfordheisler.com Miranda Katz, Associate 646-401-0475 [email protected] New York | Washington, DC | San Francisco | Palo Alto | Nashville | San Diego October 30, 2025 VIA ELECTRONIC FILING Re: Sabic-El-Rayess v. Tchrs. Coll., Columbia Univ., No. 1:24-cv-02891-JMF (S.D.N.Y.) Dear Judge Furman: Plaintiff Dr. Amra Sabic-El-Rayess hereby moves to file Exhibits A and C to her October 30, 2025 Letter Motion to Compel under seal, and to redact related portions of her motion. Immediately after filing this Motion to File Under Seal, Plaintiff will (1) file under seal a fully visible and unredacted version of her October 30, 2025 Letter Motion to Compel and accompanying exhibits, and (2) publicly file a not-fully-visible and partially redacted version of her October 30, 2025 Letter Motion to Compel and accompanying exhibits. Exhibit A is an expert report prepared by Dr. Jacqueline Bashkoff, the rebuttal emotional distress expert retained by Defendant Teachers College, Columbia University. The report contains a psychological evaluation of Plaintiff and addresses sensitive information regarding her health, mental health, personal history, and family. Exhibit C is the scores and answer sheet for the Minnesota Multiphasic Personality Inventory-2 (MMPI-2), a psychometric test that Dr. Bashkoff administered to Plaintiff. Plaintiff's October 30, 2025 Letter Motion to Compel quotes portions of Exhibit A that interpret Dr. Sabic-El-Rayess’s MMPI-2 results. A three-part test applies to whether documents may be placed under seal: (1) whether the “the documents at issue are indeed ‘judicial documents’ . . . and that therefore a common law presumption of access attaches”; (2) “the weight of that presumption”; and (3) “balanc[ing] competing considerations” such as “the privacy interests of those resisting disclosure.” Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006). To be considered a judicial document, a document “must be relevant to the performance of the judicial function and useful in the judicial process.” /d. at 115 (quotations omitted). Here, the documents filed under seal and redacted are of little relevance to the performance of the judicial function at this stage. Even if Exhibits A and C are judicial documents, the Court must also consider the weight of the presumption of access for the records at issue. Here, none of these documents are publicly available, nor would the public expect them to be so. Rather, these documents concern Dr. Sabic- El-Rayess’s psychological functioning and psychosocial history, including sensitive details regarding her family, children, symptomatology, and MMPI-2 profile. Finally, the Court must balance competing interests against the presumption of public access, including “the privacy interests of those resisting disclosure.” Olsen v. Major League

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Baseball,

(2d Cir. 2022). Here, Dr. Sabic-El-Rayess has a substantial privacy interest in documents detailing her psychological history and functioning. This “privacy interest .. . outweighs the public’s interest in full access to these documents.” Spring v. Allegany- Limestone Cent. Sch. Dist., No. 14-CV-476S,

, at *1 (W.D.N.Y. Sept. 14, 2021) (granting motion to seal psychological evaluation); see also United States v. Hernandez, No. CR- 3:23-MJ-00655 (TOF),

, at *4 (D. Conn. Feb. 21, 2024) (same); United States v. Vejvoda, No. 5:08-CR-240 (FJS),

, at *5 (N.D.N.Y. Oct. 3, 2008) (same); United States v. Bliss, No. 1:05-CR-541 (FJS),

, at *5 (N.D.N.Y. Oct. 9, 2007) (same). Plaintiff respectfully requests that Exhibits A and C remain filed under seal, and that the portions of Plaintiff's October 30, 2025 Letter Motion to Compel quoting Exhibit A remain redacted. Respectfully submitted, /s/ Miranda Katz MIRANDA KATZ GRANTED. The Clerk of Court is directed DAVID SANFORD terminate ECF No. 143. SO ORDERED. MICHAEL PALMER CAROLIN GUENTERT ALOK NADIG SANFORD HEISLER Novelmiser 3, 2025 SHARP MCKNIGHT, LLP 17 State Street, 37" Floor New York, New York 10004 Telephone: (646) 402-5650 [email protected] [email protected] [email protected] [email protected] [email protected] Attorneys for Plaintiff Dr. Amra Sabic-El-Rayess