In re AmTrust Financial Services, Inc. Securities Litigation

Opinion

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LAW OFFICES WILLIAMS & CONNOLLY ue: AMANDA M. MACDONALD 680 MAINE AVENUE SW EDWARD BENNETT WILLIAMS (1920-1988) (202) 434-5416 PAUL R. CONNOLLY (1922-1978) amacdonaid@wce.com WASHINGTON, DC 20024 = a 202.434.5000 USDC SDNY DOCUMENT 1 T December 22, 2025 ELECTRONICALLY FILED | VIA ECF DOC #: BME | 4 4 □ The Honorable Lewis A. Kaplan DATE FILED: ll United States District Court for the Southern District of New York Daniel Patrick Moynihan United States Courthouse 500 Pearl Street New York, NY 10007-1312 Re: Inre AmTrust Financial Services, Inc. Securities Litigation - No. 1:17-cv-01545- LAK (S.D.N.Y.) Dear Judge Kaplan: We write on behalf of the AmTrust and Underwriter defendants to seek the Court’s provisional approval to file certain materials under seal pursuant to the Protective Order Restricting Disclosure of Confidential Information, Dkt. 215 (“the Protective Order”), and Your Honor’s Individual Rules of Practice. For certain of these materials, we do so at the request of Plaintiffs and non-party Depository Trust and Clearing Corporation (“DTCC”). Concurrently with the filing of this letter, the AmTrust and Underwriter defendants have filed their Opposition to Plaintiffs’ Motion for Class Certification, Certification of Subclass Representatives, and Appointment of Class Counsel, as well as the Declaration of Amanda MacDonald (the “MacDonald Declaration”) in support of the same. Certain materials referenced in the opposition and attached as exhibits to the declaration have been designated “Confidential” by the producing party pursuant the Protective Order. Those parties requested we file under seal the following materials:

SO ORDERED

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WILLIAMS & CONNOLLY ur: December 22, 2025 Page 2

Exhibit 4 (Declaration of Ann Marie DTCC Bria) Exhibit 5 (Declaration of Ken Judy) | Underwriter Defendants Exhibit 6 (DTC Participant Daily : ; Aphivity Stateutent) DTCC; Underwriter Defendants Exhibit 7 (Declaration of Nicky Lnderweltes Ceteociurts Dixon) Exhibit 13 (MS_000038841) Underwriter Defendants Exhibit 15 (JUPITER0000218) Plaintiffs Exhibit 30 (ILRT0000459) Plaintiffs

Pursuant to the Protective Order, the Underwriter Defendants respectfully seek to redact confidential information regarding the Morgan Stanley & Co. LLC’s preexisting share position in Exhibit 5 to the MacDonald Declaration, as well as account numbers for the Underwriter Defendants in both Exhibits 5 and 7 to the MacDonald Declaration. The Underwriter Defendants also respectfully request that Exhibits 6 and 13 to the MacDonald Declaration, which contains non-public information regarding the Underwriter Defendants’ transactional activities, remain fully under seal. Courts “routinely permit parties to seal or redact commercially sensitive information in order to protect confidential business and financial information.” Jn re B&C KB Holding GmbH, 2023 WL 2021299, at *1 (S.D.N.Y. Feb. 14, 2023). Such protected information can include specific details about trades or trading activity. In re Tether & Bitfinex Crypto Asset Litig., 2024 WL 3520363, at *21 (S.D.N.Y. July 24, 2024). In accordance with Your Honor’s Individual Rules of Practice regarding sealed filings, the AmTrust and Underwriter Defendants have notified Plaintiffs and DTCC that they must file within three days a letter explaining the need to seal those materials that they have designated. Unless addressed above, the AmTrust and Underwriter Defendants take no position on whether those materials designated by Plaintiffs and DTCC should remain under seal. The AmTrust and Underwriter Defendants also seek the Court’s provisional approval to redact passages of the Opposition that cite and describe the contents of these documents designated by Plaintiffs and DTCC. The AmTrust and Underwriter Defendants take no position on whether these passages of the Opposition should remain redacted.

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WILLIAMS & CONNOLLYue- December 22, 2025 Page 3 WILLIAMS & CONNOLLY LLP /s/ Amanda M. MacDonald Amanda M. MacDonald Counsel for AmTrust Defendants ROPES & GRAY LLP /s/ Gregg L. Weiner Gregg L. Weiner 1211 Avenue of the Americas New York, NY 10036 Tel: (212) 596-9000 Fax: (212) 596-9090 Counsel for Underwriter Defendants