Breaking Glass Pictures, LLC v. Sal Franciosa Productions, LLC ( 2020 )

Malar Opal i495 Marker Street, ¢ise Floor John W. Scott Philadelphia, PA rgio3-7599 Tel: 215.864.8635 TEL 207.669.8700 Fax: 215.864.8999 PAX 209.864.8909 scott] @ballardspahr.com worw.ballardspahre, com June 26, 2020 Via E-mail (ECF) Hon. Ronnie Abrams United States District Judge United States District Court for the Southern District of New York 40 Foley Square, Room 2203 New York, NY 10007 Re: Breaking Glass Pictures, LLC v. Sal Franciosa Productions, LLC, C.A. No. 20-cv- 04304 Dear Judge Abrams: I am writing on behalf of Breaking Glass Pictures, LLC, in response to the Court’s June 18, 2020 Order (Dkt. No. 10), directing Breaking Glass to submit proposed redactions to Exhibit 2 to the Petition to Confirm the Arbitration Award (Dkt. No. 2-2). Pursuant to the Court’s Individual Rule 5.A, Breaking Glass hereby requests leave to file the Distribution Agreement with the proposed redactions, per the Courts’ June 18 Order. Counsel for both parties have conferred, and counsel for SFP has consented to the proposed redactions. Because the agreement is extremely faint, we have depicted the proposed redactions without using the requested yellow highlighting in the hopes of preserving legibility. Respectfully, rw \N- Cay John W. Scott JWS/njym Attachments ce: Carrie A. Ward (via email) Stephen J. Kastenberg DMEAST #41513712 v2 Hon. Ronnie Abrams June 26, 2020 Page 2 The Court has reviewed the proposed redactions to the Distribution Agreement filed as Exhibit 2 to the Petition to Confirm the Arbitration Award. Because these redactions are "narrowly tailored" to serve the "higher values" identified by Petitioner, see Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 120 (2d Cir. 2006), Petitioner's redactions are approved, and its request to file Exhibit 2 in redacted form is granted. SO ORDERED. . —— ~+ Hon. Ronnie Abrams 6/29/2020 DMEAST #41513712 v2