In re: Subpeonas to Leeds Equity Partners and Jacques Galante

Filing 31

ORDER granting 22 Letter Motion to Seal. GRANTED SO ORDERED. The Clerk of Court is respectfully request to close the motion at ECF No. 22. (Signed by Judge Mary Kay Vyskocil on 3/12/2025) (tg)

March 11, 2025
VIA CM/ECF

Honorable Mary K. Vyskocil
Daniel Patrick Moynihan
United States Courthouse
500 Pearl St.
New York, NY 10007-1312

Re:

Norton Rose Fulbright US LLP
1301 Avenue of the Americas
New York, New York 10019-6022
United States of America
Direct line [phone]
[e-mail]
Tel [phone]
Fax [phone]

USDC SDNY
DOCUMENT
ELECTRONICALLY FILED
DOC #:
DATE FILED: 3/12/2025

Emergency Request to Seal ECF No. 13, In re Subpoenas to Leeds Equity Partners and
Jacques Galante Misc. No. 1:25-mc-00079 (S.D.N.Y.), Related to UWorld, LLC fka
USMLEWorld, LLC v. USMLE Galaxy, LLC DBA Archer Review and Tart Labs, No. 3:23cv-00447 (N.D. Tex.)

Dear Judge Vyskocil:
Pursuant to Rule 7.1(e) of the Local Rules of the United States District Courts for the Southern
and Eastern Districts of New York, the Southern District of New York’s Sealed Records Filing
Instructions, and Rule 9(B) of the Individual Rules of Practice in Civil Cases, UWorld, LLC, f/k/a
USMLEWorld, LLC (“UWorld”) respectfully submits this letter requesting the emergency sealing
of ECF No. 13. UWorld seeks to file under seal ECF No. 13. UWorld inadvertently revealed
confidential information concerning the Leeds transaction, which is not publicly known. Counsel
for Archer Review and Leeds notified UWorld of the error today, March 11, 2025. UWorld
explained the error was inadvertent and now seeks to remedy.
“Although the right of public access to court records is firmly entrenched and well supported by
policy and practical considerations, the right is not absolute.” In re Orion Pictures Corp., 21 F.3d
24, 27 (2d Cir. 1994). “Redaction may be appropriate to protect confidential information.”
Fairstein v. Netflix, Inc., No. 20-CV-8042 (PKC), 2023 WL 6164293, at *1 (S.D.N.Y. Sept. 21,
2023). This information is relevant to the Court’s decision on the parties’ discovery dispute, but
UWorld submits it should be sealed for the same reasons all information on the Leeds transaction
(other than the fact that the transaction occurred) should be sealed. See ECF Nos. 15, 20-1, 202.
Accordingly, UWorld respectfully requests that the Court seal ECF No. 13 and allow UWorld to
file Exhibit A as a replacement thereof. UWorld submits in its place a version of ECF No. 13
redacting the confidential information (describing the magnitude of the Leeds transaction).
Pursuant to the Court’s rules, UWorld also submits a sealed version of ECF No. 13 with the
proposed redactions highlighted (Ex. B). A proposed order is further included as Exhibit C.

Norton Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.

297199600.2

Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright
South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps
coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are
available at nortonrosefulbright.com.

Honorable Mary K. Vyskocil
March 11, 2025
Page 2

Respectfully submitted,

/s/ Sean M. Topping
Sean M. Topping

GRANTED
SO ORDERED.
The Clerk of Court is respectfully request to close the motion
at ECF No. 22.

Partner

3/12/2025

297199600.2