~A SPECIAL EDUCATION AND SPECIAL NEEDS PLANNING ATTORNEYS ANDREW CUDDY MANAGING ATTORNEY March 1, 2022 BENJAMIN Kopp ASSOCIATE ATTORNEY Honorable Vernon S. Broderick BKOPP(@CUDDYLAWIFIRM.COM United States District Judge DIRECT DIAL 315-207-5584 Southern District of New York Thurgood Marshall United States Courthouse 40 Foley Square, Room 415 New York, New York 10007 Re: S.S., individually and on behalf of T.S-W. v. New York City Dept. of Educ., Index No. 20-cv-9394-VSB Dear Hon. Broderick: I am counsel for the Plaintiff in this matter. Pursuant Rule 5.B.1 of Your Honor’s Individual Rules & Practices in Civil Cases, Plaintiff respectfully requests—on Defendant’s consent—leave to file under seal the record that was before the Office of State Review. Due to the volume of the record and the size limitations on ECF, the undersigned will file under seal the proposed documents (pursuant to Rule 5.B.il, separately from and contemporaneously with this public filing) as three exhibits. Exhibit A is Bates stamped RO001 — RO0107; Exhibit B is Bates stamped RO108 — RO510; and Exhibit C is Bates stamped RO511 — R0638. Thank you for your consideration of this matter. Respectfully, Pursuant to Rule 5.B.iii.b. of my Individual Rules & Practices in Civil Cases, the parties are directed to provide an explanation of the reasons for seeking to file the s/ Ben amin M. Ko documents under seal on or before March 7, 2022. To be approved, any redaction Benjamin M. Kopp, Esq. or sealing of a court filing must be narrowly tailored to serve whatever purpose justifies the redaction or sealing and must be otherwise consistent with the presumption in favor of public access to judicial documents. See, e.g., Lugosch v. Pyramid Co. of Onondaga, 435 F.3d 110, 119-20 (2d Cir. 2006). In general, the parties’ consent or the fact that information is subject to a confidentiality □□□□□□□□ between litigants is not, by itself, a valid basis to overcome the presumption in fav of public access to judicial documents. See, e.g., In re Gen. Motors LLC Ignition Switch Litig., No. 14-MD2543 (JME), 2015 WL 4750774, at *4 (S.D.N.Y. Aug. 1 2015). SO ORDERED: \ lopnusy, ‘FOvTNe iF 03/02/22 HON. VERNON S. BRODERICK UNITED STATES DISTRICT JUDGE 5693 SOUTH STREET ROAD, NEW YORK 13021 ¢ FAX: 1-888-282-7785