Vinci Brands, LLC v. Coach Servs. Inc., et al.

ORs anSTa We Gel □□□ Ww ow □□ □□ DICKINSONWRIGHTric Vibe HON. VALERIEFIGUEREDO UNITED STATES MAGISTRATE JUDGE Dated: December 1, 207 The parties' motion to seal is GRANTED. Pursuant to t filing here and at ECF No. 975, the Clerk of the Court □ respectfully directed to maintain the sealing at ECF No 953-1 and remove the restrictions from 953, 953-2, 953-3, and 953-4. The Clerk of the Court is additionall requested to maintain the sealing at ECF No. 969-1 anc remove the restrictions from 969, 969-2, 969-3, and VIA ECF 969-4. The Clerk of the Court is further directed to clos the motions at ECF Nos. 968 and 974.

The Honorable Valerie Figueredo Daniel Patrick Moynahan United States Courthouse Pearl Street New York, NY 10007 Re: Vinci Brands, LLC v. Coach Servs. Inc., et al., No. 1:23-cv-05138; Letter Seeking Sealing of Exhibit A to ECF 952 and 968 Dear Judge Figueredo: Pursuant to ECF 970, Vinci Brands, LLC and Charles Tebele (the “Moving Parties”) respectfully requests that the Exhibit E to ECF 952 and 968 remained sealed. Good cause exists to permanently seal Exhibit E, as it includes personal, confidential, and financially sensitive information. Accordingly, Vinci designated Exhibit E as “Confidential” under the Stipulation and Confidentiality Agreement and Order (“Confidentiality Agreement”) (ECF 106). Such personal, confidential, and financially sensitive information is of no value to the public and should be protected, as contemplated by the Confidentiality Agreement.

A three-part analysis determines whether a document relating to a lawsuit should be made openly available. See Lugosch v. Pyramid Co., 435 F.3d 110, 119-20 (2d Cir. 2006). If the Court determines that the materials to be sealed are judicial documents (step one), then the Court must determine the weight of the presumption of access (step two), based on the “value of such information to those monitoring the federal courts.” See id.; see also United States v. Amodeo, 71 F.3d 1044, 1049 (2d Cir. 1995). Then the Court “must balance competing considerations against” the presumption of access (step three). Lugosch, 435 F.3d at 120 (internal quotation marks and citation omitted). Because private financial information implicates significant privacy interests, such information is routinely sealed as it overcomes the strong presumption of public access. See City of Almaty, Kazakhstan v. Ablyazov, No. 15 Civ. 5345, 2021 1177737, at *2 (S.D.N.Y. March 29, 2021) (granting motion to seal private financial information).

Here, Exhibit E contains the private banking information of two individuals, Charles Tebele and Michael Haddad. Such information is precisely the type of private financial information that warrants protection by this Court.

ARIZONA CALIFORNIA COLORADO FLORIDA ILLINOIS KENTUCKY MICHIGAN NEVADA OHIO TENNESSEE TEXAS WASHINGTON DC TORONTO DICKINSON WRIGHT PLLC Hon. Valerie Figueredo November 25, 2025 Page 2 We thank you for your continued attention to this matter.

Respectfully submitted, DICKINSON WRIGHT PLLC /s/ Paul A. Del Aguila Paul A. Del Aguila One of the Counsel for Vinci Brands, LLC and Charles Tebele ARIZONA CALIFORNIA COLORADO FLORIDA ILLINOIS KENTUCKY MICHIGAN NEVADA OHIO TENNESSEE TEXAS WASHINGTON DC TORONTO