Huzhou Chuangtai Rongyuan Investment Management Partnership v. Qin

Opinion

Pillsbury Winthrop Shaw Pittman LLP 31 West 52nd Street | New York, NY 10019-6131 | tel 212.858.1000 | fax 212.858.1500

Andrew C. Smith tel: +1.212.858.1743 andrew.smith@pillsburylaw.com October 19, 2022 Via Electronic Filing The Honorable Katherine Polk Failla MEMO ENDORSED United States District Court Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square New York, NY 10007 Re: Huzhou Chuangtai Rongyuan Investment Management Partnership et al vy. Qin, Case No. 1:21-cv-09221-KPF Dear Judge Failla: On behalf of Petitioners Huzhou Chuangtai Rongyuan Investment Management Partnership, Huzhou Huihengying Equity Investment Partnership, and Huzhou Huirongsheng Equity Investment Partnership (collectively, “Petitioners”), pursuant to Your Honor’s individual rule 9(B), upon request by counsel for Respondent Hui Qin, and after review of Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110 (2d Cir. 2006) and Bernstein v. Bernstein Litowitz Berger & Grossman LLP, 814 F.3d 132 (2d Cir. 2016), we respectfully submit this letter motion to file certain documents under seal. On October 13, 2022, Petitioners filed their Motion to Dissolve Automatic Stay of Proceedings to Collect Judgment (the “Motion”). See Dkt. Nos. 49-52. In support of the Motion, Petitioners filed the Declaration of Carol Lee (“Lee Decl.”), along with four exhibits. Dkt. No. 51. On October 18, 2022, Respondent’s counsel contacted the undersigned and asked that two of the exhibits to the Lee Decl. be redacted. Specifically, Respondent’s counsel asked that Exhibits 2 and 3 to the Lee Decl. (Dkt. Nos. 51-2 and 51-3) be redacted. Petitioners consented to Respondent’s request to redact certain information in the above-referenced documents. Accordingly, pursuant to Your Honor’s individual rule 9(A), Petitioners redacted certain information in the above-referenced documents and re-filed the partially redacted versions as Dkt. Nos. 56-1 and 56-2.

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The Honorable Katherine Polk Failla October 19, 2022 Page 2 Therefore, upon request by Respondent’s counsel and given that partially redacted versions have been filed, we respectfully request that Dkt. Nos. 51-2 and 51-3 be formally sealed and removed from the docket. Respectfully submitted, /s/ Andrew C. Smith Andrew C. Smith

Application GRANTED. The Clerk of Court is directed to maintain Exhibits 2 and 3 to docket entry 51 under seal, viewable only to the parties and the Court. The Clerk of Court is further directed to terminate the motion at docket entry 57.

Dated: October 19, 2022 New York, New York