Edmar Financial Company, LLC v. Currenex, Inc.

Opinion

| UsDC SDNY HBOCU MENT A eELECTRONICALLY FILED ALSTON&BIRD: IDOC #: iy A Ett . i a 90 Park Avenue □ D ATE i LED □ New York, NY 10016 [eee nescence 212-210-9400 | Fax: 212-210-9444 Eric Kuwana Direct Dial: 212-210-9586 Email: eric.kuwana@alston.com May 12, 2026 VIA ECF The 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 10017-1312 Re: Edmar Fin. Co., LLC, et al. v. Currenex, Inc., et al., Case No. 21-cv-06598 Dear Judge Kaplan, We represent Defendants Currenex, Inc., State Street Bank and Trust Company, and State Street Global Markets International Limited in the above matter. We write on behalf of all Defendants in advance of filing a response to Plaintiffs’ request for an extension of their deadline to disclose rebuttal merits expert reports (the “Response’’). ECF No. 465. Pursuant to Federal Rule of Civil Procedure 5.2(d), this Court’s Rules, the Stipulation and Order of Confidentiality so ordered in this action on October 18, 2023, (ECF No. 113), and the Joint Stipulation and Order Regarding Class Certification Sealing and Page Limits so ordered in this action on November 13, 2025 (the “Sealing Order”) (ECF No. 387), Defendants respectfully submit this letter motion to request that Exhibit B to Defendants’ forthcoming Response be filed under seal. Exhibit B contains excerpts from the transcript of the February 6, 2026 deposition of Peter Reiss, Defendants’ damages expert, which was previously sealed pursuant to the Court’s March 2, 2026 Order (ECF No. 458). The deposition transcript has also been designated as Highly Confidential pursuant to the Parties’ Stipulation and Order of Confidentiality. See ECF No. 113. This deposition transcript reflects Defendants’ commercially sensitive and proprietary information. Defendants respectfully submit that sealing is justified under controlling legal precedent. See Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006). Artal ‘lh LEWIS A. KAPLAN, USDJ

Hon. Lewis A. Kaplan, U.S.D.J. May 12, 2026 Page 2 As always, we thank the Court for its attention to this matter. Respectfully submitted, /s/ Eric Kuwana Eric Kuwana cc: All Counsel of Record (via ECF)