In re: AXA Equitable Life Insurance Company

S.D. New York

In re: AXA Equitable Life Insurance Company

District Court, S.D. New York·Decided June 3, 2024·No. 1:16-cv-00740·Unknown

Opinion

SUSMAN GODFREY L.L.P.

LOS ANGELES, CALIFORNIA 90067-6029

DIRECT Dea oy voe-3 163 E-MaIL HJOSEPHS@SUSMANGODFREY.COM Application GRANTED, subject to reconsideration in the event that a1 May 31, 2024 party or third party files a motion to unseal a particular document or documents. The Clerk is directed to terminate ECF No. 742. Hon. Jesse M. Furman United States District Court SOO RED. Southern District of New York 40 Centre Street, Room 2202 New York, NY 10007 une 3, 2024 Re: = Brach Family Found., Inc., et al. v. AXA Equitable Life Ins. Co., No. 16 Civ. 740 (JMF) Dear Judge Furman: Class Counsel in the above-captioned action offers this letter-motion to seal pursuant to Rule 7.B of Your Honor’s Individual Rules and Practices in Civil Cases regarding Class Counsel’s Motion to Authorize Additional Steps to Allocate Class Action Settlement Funds, the accompanying Memorandum of Law, Declaration of Halley Josephs in Support of the Motion, Exhibits 1-8 to the Declaration, and Proposed Order. The redacted Memorandum of Law, Declaration, and Proposed Order, and fully sealed Exhibits reflect confidential information identifying Final Class Members and the policies owned by them. This information was designated “Confidential” by AXA pursuant to the terms of the protective order as well as by securities intermediaries who produced identifying information regarding Substituted Illustration Class Members in response to subpoenas authorized by the Court. Dkt. 672. In light of the privacy and confidentiality interests of absent class members, Class Counsel respectfully requests that the material redacted from the Memorandum of Law, Declaration, and Proposed Order, and Exhibits 1—8 in their entirety, remain under seal. See Dkt. 646 (granting application to seal confidential information regarding class member identities); cf. Awestruck Mktg. Grp., LLC v. Black Ops Prods., LLC, No. 16-CV-3639, 2016 WL 8814349, at *3 (S.D.N.Y. June 20, 2016).

May 31, 2024 Page 2

Sincerely,

/s/ Halley Josephs Halley Josephs

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SUSMAN GODFREY L.L.P.

LOS ANGELES, CALIFORNIA 90067-6029

DIRECT Dea oy voe-3 163 E-MaIL HJOSEPHS@SUSMANGODFREY.COM Application GRANTED, subject to reconsideration in the event that a1 May 31, 2024 party or third party files a motion to unseal a particular document or documents. The Clerk is directed to terminate ECF No. 742. Hon. Jesse M. Furman United States District Court SOO RED. Southern District of New York 40 Centre Street, Room 2202 New York, NY 10007 une 3, 2024 Re: = Brach Family Found., Inc., et al. v. AXA Equitable Life Ins. Co., No. 16 Civ. 740 (JMF) Dear Judge Furman: Class Counsel in the above-captioned action offers this letter-motion to seal pursuant to Rule 7.B of Your Honor’s Individual Rules and Practices in Civil Cases regarding Class Counsel’s Motion to Authorize Additional Steps to Allocate Class Action Settlement Funds, the accompanying Memorandum of Law, Declaration of Halley Josephs in Support of the Motion, Exhibits 1-8 to the Declaration, and Proposed Order. The redacted Memorandum of Law, Declaration, and Proposed Order, and fully sealed Exhibits reflect confidential information identifying Final Class Members and the policies owned by them. This information was designated “Confidential” by AXA pursuant to the terms of the protective order as well as by securities intermediaries who produced identifying information regarding Substituted Illustration Class Members in response to subpoenas authorized by the Court. Dkt. 672. In light of the privacy and confidentiality interests of absent class members, Class Counsel respectfully requests that the material redacted from the Memorandum of Law, Declaration, and Proposed Order, and Exhibits 1—8 in their entirety, remain under seal. See Dkt. 646 (granting application to seal confidential information regarding class member identities); cf. Awestruck Mktg. Grp., LLC v. Black Ops Prods., LLC, No. 16-CV-3639, 2016 WL 8814349, at *3 (S.D.N.Y. June 20, 2016).

May 31, 2024 Page 2

Sincerely,

/s/ Halley Josephs Halley Josephs

In re: AXA Equitable Life Insurance Company, (S.D.N.Y. 2024).

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