S.W. v. Kristi Noem, et al.

DavisPolk Sesfiriirere blake, □□□□□□□□□□□□□□□□□□□□□□ New York, NY 10047 davispalk.corn November 6, 2025 pnd oe. pec Re: S.W. v. Kristi Noem, et ail., No. 1:25-cv-09264 cpu pode Hon, P. Kevin Castel bet □ United States District Court for the Southern District of New York eres, Peari Street - fee New York, NY 10007 “ind un □□□□ Dear Judge Castel: pom 7a We represent Plaintiff S.W. in the above-referenced action. Plaintiff respectfully requests permission to file certain materials under seal. Specifically, for the reasons set forth below, Plaintiff respectfully requests to □□ ‘fl file under permanent seal all exhibits to the Declaration of Blake E, Andersen in Support of Plaintiff's Application for a Temporary Restraining Order and Preliminary Injunction, filed contemporaneously □ pEnel herewith. @ □□ och Lie □□ Exhibits A-F and H reveal Plaintiff's identity, A-number, address, and sensitive informati oncésing his asylum claim. Plaintiff has filed a Motion for Leave to Proceed Using Initials [ECF No. 6] in this matter due //- {5 to the highly sensitive and personal information underlying his asylum claim. Plaintiff faces “the risk of retaliatory physical or mental harm’ if his identity were to be publicly disclosed. Motion for Leave fo Proceed Using Initials at 5 (quoting Sealed Plaintiff v. Sealed Defendant, 537 F.3d 185, 190 (2d Cir, 2008)), For the reasons set forth in the Mofion for Leave to Proceed Using Initials, Plaintiff respectfully submits that the aforementioned exhibits, which reveal Plaintiff's name and sensitive, personally identifying Information related to his asylum claim, should be sealed.

Additionally, Exhibit G is a declaration from an immigration attorney, Ms. Greenberg, detailing events concerning her detained client. As it is possible to discern Ms. Greenberg's client's identity from the details in Exhibit G, Plainiiff respectfully submits that Exhibit G should be sealed for reasons consistent with Plaintiff's Molion for Leave to Proceed Using Initials.

Plaintiff has conferred with Defendants’ counsel, informing them of the request to seal and transmitting unredacted copies of Exhibits A-H. Defendants’ counsel has informed me that Defendants do not take a position on this letter motion fo seal.

Plaintiff respectfully requests that the Court so order this letter fo grant the foregoing request. We are available at the Court's convenience should Your Honor have any questions.

Respectfully yours, /s/ Blake E. Andersen Blake E. Andersen Electronic Filing