`
`
`
`125 Broad Street
`New York, New York 10004-2498
`
`______________________
`
`LOS ANGELES • PALO ALTO • WASHINGTON, D.C.
`
`BRUSSELS • FRANKFURT • LONDON • PARIS
`
`BEIJING • HONG KONG • TOKYO
`
`MELBOURNE • SYDNEY
`
`April 5, 2025
`
`
`
`TELEPHONE: 1-212-558-4000
`FACSIMILE: 1-212-558-3588
`WWW.SULLCROM.COM
`
`
`
`
`
`Via E-mail
`
`The Honorable Analisa Torres,
`United States District Court for the
`Southern District of New York,
`500 Pearl Street,
`New York, New York 10007-1312
`
`Re: United States v. Guo, et al.,
`No. 23 Cr. 118 (AT) (S.D.N.Y.)
`
`Dear Judge Torres:
`
`I represent petitioners (1) Mercantile Global Holdings, Inc. and (2) James
`R. Collins, Jr., on behalf of the following shareholders of Mercantile Global Holdings
`stock: Morpheus Asset Strategies LLC; Galaxy Digital Ventures LLC; Options Technology
`Solutions International LLC d/b/a Mercury Digital Assets; BTG Trading Ltd., Dave Chen;
`Thomas Becker; International Sports LLC; Robert Doyle; Arturo Ganteaume; Jeremy
`Cunningham; Jeff Lee; Eric Edwards; Brittany Hickman; Myla Johnson; Mirstar, LLC;
`Don Cornwell; Netonis Wybensinger; Kevin Long; and Yarot Lafontaine, (collectively, the
`“Petitioners”) with respect to the two Ancillary Petitions filed on April 5, 2025 by each
`party. See ECF Nos. 616 and 617.
`
`On behalf of Petitioners and in accordance with Rule IV.A.ii of Your
`Honor’s Individual Practices in Civil Cases, I request that the Court permit the filing under
`seal of Exhibits 1 through 4 of the Ancillary Petitions filed on behalf of the Petitioners, i.e.
`ECF Nos. 616 and 617. These exhibits contain sensitive personal information for the
`shareholders as well as other sensitive business information not relevant to these
`proceedings. Filing the exhibits under seal will protect the substantial privacy interests of
`the 19 individual shareholders listed above and Mercantile Global Holdings, Inc.’s
`commercially sensitive business information, and the public interest would not be served
`by the disclosure of this information, which, again, is unrelated to the issues in Petitioners’
`Ancillary Petitions.
`
`
`
`
`
`
`
`
`
`Case 1:23-cr-00118-AT Document 618 Filed 04/05/25 Page 2 of 2
`
`
`The Honorable Analisa Torres,
`
`
`
`-2-
`
`For the foregoing reasons, Petitioners respectfully ask the Court for
`permission to file Exhibits 1-4 of ECF Nos. 616 and 617 under seal.
`
`
`
`Respectfully submitted,
`
`/s/ Sharon Cohen Levin .
`Sharon Cohen Levin
`SULLIVAN & CROMWELL LLP
`125 Broad Street
`New York, NY 10004
`Tel: (212) 558-4334
`Email: levinsc@sullcrom.com
`Attorney for Petitioners
`
`
`cc:
`
`
`All parties of record (by ECF)
`
`
`
`

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