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MAAUEL trial lawyers | new york USDC SDN¥s sth Avenue, New York, New York 10016-7103 | TEL (212) 849-7000 FAX (212) 849-7100 DOCUMENT ELECTRONICALLY FILED | DOC #: | WRITER’S DIRECT DIAL|NO. a (212) 849-7345 DATE FILED: | WRITER’S EMAIL ADDRESS | cues October 28, 2025 By ECF Honorable Lewis A. Kaplan United States District Judge Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street Court Room 21B New York, NY 10007-1312 Re: Edmar Financial Company, LLC et al v. Currenex, Inc. et al, Case No. 21-cv-06598 | Plaintiffs’ Response to Defendants’ Letter Motion to Seal (ECF No. 354) Dear Judge Kaplan: On behalf of Plaintiffs, we respectfully submit this response to request three exhibits and the relevant portions of Defendants’ response filed at ECF No. 355 (the “Response”) remain under seal. See ECF Nos. 354 (letter motion to seal), 355 (Response referencing Exhibits), and 35 St, 355-2, and 355-3 (the “Exhibits” at issue). We designated the Exhibits as “Highly Confidential” pursuant to the Court’s Protective nie, ECF No. 113, because they include information concerning confidential and non-public communications regarding potential litigation. Documents should remain sealed if “closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Lugosch v. Pyramid Co. of Onondaga,

(2d Cir. 2006) (citation omitted). There is significant public interest in maintaining the confidentiality of communications between attorney and client and “this is precisely the kind of countervailing concern that is capable of cole the general preference for public access to judicial records.” Diversified Grp., Inc. v. Daugerdas,

(S.D.N.Y. 2003) (citation omitted). Plaintiffs also seek to avoid any iba of the confidentiality of communications involving law firms not present in the case. For all the reasons set forth above, the Court should order that the Exhibits and references in Defendants’ Response remain sealed.

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Respectfully submitted, /s/ Daniel L. Brockett Daniel L. Brockett cc: Counsel of Record