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

: One North Broadway, Suite 900 B CG | Finkelstein, Blankinship, WHITE PLAINS, NY 10601 }: . Phone: (914) 298-3281 Frei-Pearson & Garber, LLP Faw (345) 562.3492 www. fbfplaw.com November 17, 2025 BY ECR Hon. Paul A. Engelmayer United States District Judge Foley Square New York, NY 10007 Re: Castillo et al v. Albert Einstein College of Medicine Inc. et al, No, 1:24-cy-0984 Dear Judge Engelmayer, Pursuant to Your Honot’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 Plaintiffs 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 Procedure 26(c) authorizes district courts, upon a showing of good cause, to “require that the patties 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 », 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.” [d, (internal quotations omitted).

Here, Plaintiff seeks leave to file PlaintifPs declaration which contains the names of other potentially affected employees who have not publicly joined this lawsuit. ‘This request is narrowly tailored in that it relates only identifying information for individuals who are affected by this lawsuit.

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

Dated: November 17, 2025 Respectfully submitted, By: Ls Jeremiah Frei-Pearson Jeremiah Frei-Pearson Erin Kelley FINKELSTEIN, BLANKINSEIIP, 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 Mepan Jones SEPPINNI LAW Broad St., 7th FL New York, NY 10004 ‘Tel: (212) 859-5085 [email protected] [email protected] Attorneys for Plaintiff and the Putative Collective CC: All Counsel of Records via ECF GRANTED. Because plaintiff's request is narrowly tailored to protect the privacy interests of nonparties to this action, it is granted, SO ORDERED, Pru PAULA. YEE United States District Judge Date: November 19, 2025 New York, New York