KING & SPALDING King & Spalding LLP 1185 Avenue of the Americas, 34th Floor New York, NY 10036-4003 January 13, 2023 Tel: +1 212 556 2100 ° Fax: +1 212 556 2222 VIA ECF www.kslaw.com Mark A. Kirsch The Honorable Lorna G. Schofield Partner . oe Direct Dial: +1 212 790 5329 United States District Court Direct Fae 41212 556.999 Southern District of New York MKirsch@kslaw.com 500 Pearl Street New York, NY 10007 (212) 805-0288 Re: Manbro Energy Corp. v. Chatterjee Advisors, LLC, No. 20 Civ. 3773 (LGS) (S.D.N.Y.) Dear Judge Schofield: I write respectfully on behalf of Defendants regarding the Court’s January 9, 2023 Order, Dkt. No. 301, which (among other things) seeks Manbro’s position regarding the sealing of Exhibit A to the Declaration of Mark A. Kirsch in Opposition to Plaintiff's Motions in Limine. Defendants previously sought leave to file Exhibit A under seal, see Dkt. No. 274, and respectfully request that this exhibit remain sealed. Exhibit A contains “[i]nformation . . . that [Defendants] reasonably and in good faith believe[] contains or would disclose non-public, confidential, proprietary, financial, .. . or commercially sensitive information.” Dkt. No. 51 § 1.3. Specifically, this exhibit includes confidential and personal information regarding non-party investors in Haldia Petrochemicals Ltd., which is also a non-party. See Dkt. No. 278-1. This information is properly regarded as confidential and subject to sealing. See Kewazinga Corp. v. Google LLC, 2020 WL 8224932, at *1 (S.D.N.Y. July 22, 2020) (granting request to file exhibits under seal “to prevent the unauthorized dissemination of the parties’ confidential business information . . . and third-party confidential business information and personal information”); see also United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) (“the privacy interests of innocent third parties should weigh heavily in a court’s balancing equation” when deciding a motion to seal). The Court has previously granted motions to seal similar information, see Dkt. Nos. 94, 215, 302. Accordingly, Defendants respectfully request that Exhibit A remain sealed. We thank the Court for its consideration of this request. Respectfully, /s/ Mark A. Kirsch Mark A. Kirsch Ce: All counsel of record (via ECF) Application GRANTED for substantially the reasons stated above. The Clerk of Court is respectfully directed to maintain under seal all documents currently filed under seal. Dated: January 18, 2023 y Of J. Li