Rinaldys Castillo et al v. Albert Einstein College of Medicine Inc. et al

; scht One North Broadway, Suite 900 FE B G Finkelstein, Blankinship, WHITE PLAINS. NY 10601 I Frei-Pearson & Garber, LLP hone: (43) 560.3102 www, fbiglaw.comn November 17, 2025 _ BY ECF Hon. Paul A. Engelmayer United States District Judge Foley Square New York, NY 10007 Re: Castillo et al y, Albert Einstein College of Medicine Inc. et al, No, 1:24-cv-0984 Dear Judge Engelmayer, Pursuant to Your Honovr’s Individual Rules and Practices, the Local Rules of the Southern District of New York, and the Southern District’s Electronic Case Filing Rules & Instructions § 6, Plaintiff Rinaldys Castillo respectfully submits this request to file under seal an unredacted version of the exhibits attached to Jeremiah Frei-Pearson’s declaration in support of his conditional certification motion, and to file a redacted version of this submission as the publicly available filing.

In accordance with the above-referenced Rules, an unredacted version of the above referenced document along with a redacted version are being filed contemporaneously with this request, and copies of this letter and the unredacted and redacted versions of the above-referenced document shall be contemporaneously mailed to Your Honor.

Although there is a presumption of public access to judicial documents, Federal Rule of Civil Procedute 26(c) authorizes district courts, upon a showing of good cause, to “require that the parties simultaneously file specified documents or information in sealed envelopes, to be opened as the court directs.” Fed. R. Civ. P. 26(c}(1}(H). “Documents may be sealed if specific, on the record findings are made demonstrating that closure is essential to preserve higher values and is narrowly tailored to serve that interest.” Lygosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006) (internal quotations and alterations omitted). ‘These “countervailing factors include but are not limited to... the privacy interests of those resisting disclosure.” Id (internal quotations omitted).

Here, Defendants have designated some of the materials included as exhibits as Confidential.

This request is narrowly tailored in that it relates only identifying information for individuals who are affected by this lawsuit. Plaintiffs take no position for the purpose of this filing as to whether these materiais were properly designated by Defendants and reserve all tights to challenge any such designation.

Based on the foregoing, Plaintiff respectfully requests that: (i) the Court approves this request to file documents under seal; (11) the redacted version of the exhibits; and (iit) that the Court grant Plaintiff leave to file the un-redacted version of the same under seal.

Dated: November 17, 2025 Respectfully submitted, By: [sf Jeremiah Frei-Pearson Jeremiah Frei-Pearson Erin Kelley FINKELSTEIN, BLANKINSHIP, FREI-PEARSON & GARBER, LLP North Broadway, Suite 900 White Plains, New York 10601 Tel: (914) 298-3281 Fax: (914) 824-1561 [email protected] [email protected] Shane Seppinni Megan Jones SEPPINNI LAW Broad St., 7th FI, New York, NY 10004 Tel: (212) 859-5085 [email protected] [email protected] Attorneys for Plaintiff and the Putative Collective The Court is in receipt of this motion to seal. It appears that plaintiff publicly filed the relevant declaration with certain exhibits attached and others, which are the subject of this motion, omitted and denoted as "filed under seal." Dkt. 80. Because plaintiff seeks to file redacted exhibits and does not seek to seal such exhibits in their entirety, plaintiff is directed to publicly file the redacted version of those exhibits, as required by the Court's Individual Rules. Upon such filing, the Court will review this motion.

SO ORDERED.

PAUL A, ENGELMAYER United States District Judge Date: November 19, 2025 New York, New York