At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2025 Index No. 654959/2021 The Honorable Andrew J. Borrok

OF FRANK FUNDS TRUST, Individually and On Behalf of All Others Similarly Situated,

Upon the annexed (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt (“Moving Affirmation”); (ii) the Memorandum of Law In Support of Plaintiffs’ Order to Show Cause to Provisionally Seal Documents cited in Plaintiffs’ Motion for an Order to Show Cause Compelling Defendants Morgan Stanley & Co. LLC (“Morgan Stanley”), Goldman Sachs & Co. LLC (“Goldman Sachs”), Wells Fargo Securities, LLC (“Wells Fargo”) (and together “Defendants”) and Non-Party Hughes Hubbard & Reed LLP (“HHR”) to Comply With the Court’s September 27 Order and to Produce Documents Improperly Withheld As Privileged (the “Motion”); and (iii) upon all prior papers and proceedings in connection with the above-captioned action, and sufficient cause having been alleged, it is hereby: ORDERED that the Defendants, HHR, J.P. Morgan Securities, LLC (“JP Morgan”) and Intesa Sanpaolo, S.P.A. (“Intesa”) show cause before this Court at IAS Part 53 thereof, to be held in and for the County of New York, at the Courthouse, 60 Centre Street, Room 655, New York, NY 10017, at ________ on the __ day of __________, 2025, or as soon thereafter as counsel may be heard why an order should be entered sealing the Memorandum of Law In Support of Plaintiffs’ Motion and Exhibits 2-6, 14-16 and 25 to the Motion, which were designated confidential by Defendants and HHR under paragraph 12(a) of the Stipulation and Order for the Production and Exchange of Confidential Information (NYSCEF Doc. No. 275) (the “Designated Confidential Documents’); ORDERED that pending the hearing on this Order to Show Cause, these designated confidential documents will remain temporarily under seal, accessible only to the parties, their counsel, and court personnel.

And proper cause being alleged, it is hereby: ORDERED that service of a copy of this Order and the papers upon which it is based upon Defendants, HHR, JP Morgan, and Intessa by electronic filing on the NYSCEF system shall be seemed good and sufficient service thereof;

At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2025 Index No. 654959/2021 The Honorable Andrew J. Borrok

OF FRANK FUNDS TRUST, Individually and On Behalf of All Others Similarly Situated,

At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2025 Index No. 654959/2021 The Honorable Andrew J. Borrok

OF FRANK FUNDS TRUST, Individually and On Behalf of All Others Similarly Situated,

Upon the annexed (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt (“Moving Affirmation”); (ii) the Memorandum of Law In Support of Plaintiffs’ Order to Show Cause to Provisionally Seal Documents cited in Plaintiffs’ Motion for an Order to Show Cause Compelling Defendants Morgan Stanley & Co. LLC (“Morgan Stanley”), Goldman Sachs & Co. LLC (“Goldman Sachs”), and Wells Fargo Securities, LLC (“Wells Fargo”) to Produce Documents Related To Archegos Improperly Withheld As Privileged (the “Motion”); and (iii) upon all prior papers and proceedings in connection with the above-captioned action, and sufficient cause having been alleged, it is hereby: ORDERED that the Parties show cause before this Court at IAS Part 53 thereof, to be held in and for the County of New York, at the Courthouse, 60 Centre Street, Room 655, New York, NY 10017, at ________ on the __ day of __________, 2025, or as soon thereafter as counsel may be heard why an order should be entered sealing Plaintiffs’ Memorandum of Law in Support of their Motion for an Order to Show Cause Compelling Defendants Morgan Stanley & Co. LLC, Goldman Sachs & Co., LLC and Wells Fargo Securities, LLC to Produce Documents Related to Archegos Improperly Withheld as Privileged and Exhibits 1-10, 13-14, 19, 21-23, 33, 38-71 to the Motion, which were designated confidential by Defendants under paragraph 12(a) of the Stipulation and Order for the Production and Exchange of Confidential Information (NYSCEF Doc. No. 275) (the “Designated Confidential Documents’); ORDERED that pending the hearing on this Order to Show Cause, these designated confidential documents will remain temporarily under seal, accessible only to the parties, their counsel, and court personnel.

And proper cause being alleged, it is hereby: ORDERED that service of a copy of this Order and the papers upon which it is based upon Defendants by electronic filing on the NYSCEF system shall be seemed good and sufficient service thereof.

FRANKFUNDSTRUST,Individually and on Behalf of All Others Similarly Situated, Plaintiffs,

WHEREAS,pursuant to an Amended Scheduling Order dated September 24, 2024 (the "Amended Scheduling Order"), WHEREAS,pursuant depositions shall be completed by January 15, 2025; to the current schedule, fact discovery shall be completed by January 24, 2025; WHEREAS,pursuant to the current schedule, Interrogatories seeking the claims and contentions of the opposing party shall be served by March 26, 2025 and Responses to such interrogatories shall be served by April WHEREAS,pursuant 28, 2025; to the current schedule, opening expert reports were due to be served on February 14, 2025 and rebuttal WHEREAS,pursuant reports were to be filed by May 7, 2025; to the current schedule, expert discovery shall be completed June 6, 2025; WHEREAS,pursuant to the current schedule, the Note of Issue and Certificate of Readiness shall be served by June 23, 2025; WHEREAS,pursuant to the current schedule, dispositive motions shall be served within 30 days of the Note of Issue; WHEREAS,pursuant to the Amended Scheduling Order, the parties agreed to meet and confer to discuss the issues for which each party bears the burden of proof and intends to call an and expert witness; WHEREAS,the parties met and conferred on multiple occasions to discuss the most efficient way to conduct expert discovery in this action given the complexity of the issues raised in the action; WHEREFORE,subject to Court approval the parties have agreed as follows:

The parties shall disclose the subject matters for which they intend to call an expert witness by February 14, 2025, and shall within a reasonable time thereafter confer regarding the date on which the report(s) corresponding to such subject matters shall be submitted in accordance with the schedule set forth below.

The Note of Issue and Certificate of Readiness shall be served by July 28, 2025.

Dispositive motions shall be served within 30 days of the Note of Issue.

FRANK FUNDS TRUST, Individually and on Behalf of All Others Similarly Situated,

WHEREAS, pursuant to an Amended Scheduling Order dated September 24, 2024 (the “Amended Scheduling Order”), depositions shall be completed by January 15, 2025; WHEREAS, pursuant to the current schedule, fact discovery shall be completed by January 24, 2025; WHEREAS, pursuant to the current schedule, Interrogatories seeking the claims and contentions of the opposing party shall be served by March 26, 2025 and Responses to such interrogatories shall be served by April 28, 2025; WHEREAS, pursuant to the current schedule, opening expert reports were due to be served on February 14, 2025 and rebuttal reports were to be filed by May 7, 2025; WHEREAS, pursuant to the current schedule, expert discovery shall be completed June 6, 2025; WHEREAS, pursuant to the current schedule, the Note of Issue and Certificate of Readiness shall be served by June 23, 2025; WHEREAS, pursuant to the current schedule, dispositive motions shall be served within 30 days of the Note of Issue; WHEREAS, pursuant to the Amended Scheduling Order, the parties agreed to meet and confer to discuss the issues for which each party bears the burden of proof and intends to call an expert witness; and WHEREAS, the parties met and conferred on multiple occasions to discuss the most efficient way to conduct expert discovery in this action given the complexity of the issues raised in the action; WHEREFORE, subject to Court approval the parties have agreed as follows:

The parties shall disclose the subject matters for which they intend to call an expert witness by February 14, 2025, and shall within a reasonable time thereafter confer regarding the date on which the report(s) corresponding to such subject matters shall be submitted in accordance with the schedule set forth below.

The Note of Issue and Certificate of Readiness shall be served by July 28, 2025.

Dispositive motions shall be served within 30 days of the Note of Issue.

CAMELOT EVENT DRIVEN FUND,A SERIES|Index No. 654959/2021 OF FRANK FUNDS TRUST,Individually and On Behalf of All Others Similarly Situated, The Honorable Andrew J. Borrok

01/03/2025 Upon the annexed (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt (“Moving Affirmation”); (ii) the Memorandum of Law In Support of Plaintiffs’ Order to Show Cause to Provisionally Seal Documents cited in Plaintiffs’ Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC to Produce Its April Board Materials Improperly Withheld As Privileged (the “Motion”); and(iii) upon all prior papers and proceedings in connection with the above-captioned action, and sufficient cause having been alleged,it is .

hereby: ORDEREDthatthe Parties show cause before this Court at IAS Part 53 thereof, to be held in and for the County of New York,at the Courthouse, 60 Centre Street, Room 655, New York, NY 10017,at Io: 30AontheKay of Febywe KY» 2025, oras soon thereafter as counsel may be heard why an order should be entered scaling Exhibits 001-005 to the Motion, which were designated confidential by Defendants under paragraph 12(a) of the Stipulation and Orderfor the

Production and Exchange of Confidential Information (NYSCEFDoc.No.275)(the “Designated Confidential Documents’); ORDEREDthat pending the hearing on this Order to Show Cause, these designated confidential documents will remain temporarily under seal, accessible only to the parties, their — counsel, and court personnel.

And proper cause being alleged,it is hereby: ORDEREDthat service of a copy ofthis Order and the papers upon whichit is based upon Defendants by electronic filing on the NYSCEF system shall be seemed good and sufficient Answering Peis: if amg, Fy be filed on NYSCEF fricd an service thereof.

The Honorable Andrew J. Borrok

Motion Sequence No. 25 Oral Argument Requested Index No. 654959/2021

OF FRANK FUNDSTRUST,Individually and On Behalf of All Others Similarly Situated, Plaintiff,

01/03/2025 UPONthe annexed (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt in Support of Plaintiffs’ Motionfor an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC (“Morgan Stanley”) to Produce Its April Board Materials Improperly Withheld As Privileged; (ii) the exhibits attached to the Affirmation; and(iii) Plaintiffs’Memorandum of Law __ in Support oftheir-Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC (“Morgan Stanley”) to Produce Its April Board Materials Improperly Withheld As Privileged LET Defendant Morgan Stanley or any other party show cause before the Honorable Andrew Borrok, at Room 238 ofthe Courthouse located at 60 Centre Street, New York, New York, optooeat{o.30.a.m.

DATED: Ja” vary 2, 202.§ ENTER: aw ‘ Cy a

Camelot Event Driven Fund, A Series Of Frank Funds Trust, and Municipal Police Employees’ Retirement System (“Plaintiffs”), respectfully submit this memorandum of law in support of their motion by Order to Show Cause to provisionally seal Exhibits 001-005 filed in support of Plaintiffs’ Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC to Produce Its April Board Materials Improperly Withheld As Privileged, in accordance with paragraph 12(a) of the Stipulation and Order for the Production and Exchange of Confidential Information (the “Confidentiality Order”) (NYSCEF Doc. No. 275).

Good cause exists under Section 216.1 of the Uniform Rules of the New York State Trial Courts (“N.Y.C.R.R.”) to provisionally seal these exhibits pending a hearing on any motion by Defendants to maintain these documents under seal, since the documents purportedly identify and discuss information designated by Defendants as protected confidential information.

To determine whether good cause exists, “the Court shall consider the interests of the public as well as of the parties.” Id. Good cause exists here to provisionally seal the requested exhibits pending a hearing on any motion by Defendants to maintain these documents under seal.

Plaintiffs request that the Court grant the motion to provisionally seal the exhibits and to permit redaction of all text in any document filed publicly in this action quoting or describing the exhibits pending a hearing on any motion by Morgan Stanley to maintain these documents under seal.

I, John Rizio-Hamilton, an attorney duly admitted to practice law before the courts of the State of New York, hereby certify that this memorandum complies with the word count limit set forth in Commercial Division Rule 17 because it contains 660 words, excluding the parts of the memorandum exempted by Commercial Division Rule 17.

We the undersigned counsel for Plaintiffs are duly admitted to practice in the State of New York and are not parties to this action.

We are fully familiar with the facts stated in this affirmation, which is submitted in support of the application of Camelot Event Driven Fund, a Series of Frank Funds Trust, and Municipal Police Employees’ Retirement System (“Plaintiffs”) to provisionally seal Exhibits 001- 005 to Plaintiffs’ Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC to Produce Its April Board Materials Improperly Withheld As Privileged in accordance with the Stipulation and Order for the Production and Exchange of Documents (the “Confidentiality Order”) and to permit redaction of all text in any document filed publicly in this action quoting or describing the exhibits.

In accordance with paragraph 12 of the Confidentiality Order, Plaintiffs are filing by order to show cause its motion to provisionally seal the exhibits, and permit redactions of any text quoting or describing such exhibits pending a hearing on any motion by Morgan Stanley to maintain these documents under seal.

Plaintiffs stand ready to submit any additional information that the Court may require in support of the foregoing application.

WHEREFORE, for the foregoing reasons it is respectfully requested that this Court grant Plaintiffs’ motion to provisionally seal the exhibits or any excerpts of the exhibits pending a hearing on any motion by Morgan Stanley to maintain these documents under seal.

At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2024 Index No. 654959/2021 The Honorable Andrew J. Borrok

OF FRANK FUNDS TRUST, Individually and On Behalf of All Others Similarly Situated,

Upon the annexed (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt (“Moving Affirmation”); (ii) the Memorandum of Law In Support of Plaintiffs’ Order to Show Cause to Provisionally Seal Documents cited in Plaintiffs’ Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC to Produce Its April Board Materials Improperly Withheld As Privileged (the “Motion”); and (iii) upon all prior papers and proceedings in connection with the above-captioned action, and sufficient cause having been alleged, it is hereby: ORDERED that the Parties show cause before this Court at IAS Part 53 thereof, to be held in and for the County of New York, at the Courthouse, 60 Centre Street, Room 655, New York, NY 10017, at ________ on the __ day of __________, 2025, or as soon thereafter as counsel may be heard why an order should be entered sealing Exhibits 001-005 to the Motion, which were designated confidential by Defendants under paragraph 12(a) of the Stipulation and Order for the Production and Exchange of Confidential Information (NYSCEF Doc. No. 275) (the “Designated Confidential Documents’); ORDERED that pending the hearing on this Order to Show Cause, these designated confidential documents will remain temporarily under seal, accessible only to the parties, their counsel, and court personnel.

And proper cause being alleged, it is hereby: ORDERED that service of a copy of this Order and the papers upon which it is based upon Defendants by electronic filing on the NYSCEF system shall be seemed good and sufficient service thereof.

JOHN RIZIO-HAMILTON and DANIELLA QUITT, attorneys licensed to practice law in the State of New York, and not parties to the above-captioned action, affirm that the following is true under penalty of perjury pursuant to CPLR 2106:

John Rizio-Hamilton is a partner of the law firm of Bernstein Litowitz Berger & Grossmann LLP (“BLB&G”), located at 1251 Avenue of the Americas, 44th Floor, New York, NY 10020, and counsel for Plaintiff Municipal Police Employees’ Retirement System.

We submit this joint Affirmation in Support of Plaintiffs’ Motion for an Order to Show Cause Compelling Defendant Morgan Stanley & Co. LLC to produce its April Board Materials improperly withheld as privileged.

Attached as Exhibit 5 is a true and correct copy of Defendant Morgan Stanley & Co. LLC’s March 30, 2021 board of directors meeting summary bearing bates-stamp MS0000275614-617.

Attached as Exhibit 6 is a true and correct copy of an email from Defendant’s Morgan Stanley & Co. LLC’s counsel, Scott D. Musoff, dated November 13, 2024.

The following e-filed documents, listed by NYSCEF document number (Motion 029) 834, 835, 836, 837, 838, 839, 840, 841, 842, 843, 844, 845, 846, 847, 848, 849, 850, 851, 852, 853, 854, 855, 856, 857, 858, 859, 860, 861, 862, 863, 864, 865, 866, 867, 868, 869, 870, 871, 872, 873, 874, 875, 930, 972, 973, 982, 983, 984, 985, 986, 987, 988, 989, 990, 991, 992, 993, 994, 995, 996, 997, 998, 999, 1000, 1001, 1002, 1003, 1004, 1005, 1006, 1007, 1008, 1009, 1010, 1011, 1012 were read on this motion to/for

The following e-filed documents, listed by NYSCEF document number (Motion 030) 876, 877, 878, 879, 880, 881, 882, 883, 884, 885, 886, 887, 888, 889, 890, 891, 892, 893, 894, 895, 896, 897, 931, 936, 939, 940, 941, 942, 943, 944, 945, 946, 947, 948, 949, 950, 951, 952, 953, 954, 955, 956, 957, 958, 959, 960, 961, 962, 963, 964, 965, 966, 967 were read on this motion to/for

654959/2021 CAMELOT EVENT DRIVEN FUND, A SERIES OF FRANK FUNDS TRUST vs.

Page 1 of 2 Motions withdrawn without prejudice.

654959/2021 CAMELOT EVENT DRIVEN FUND, A SERIES OF FRANK FUNDS TRUST vs.

For the reasons set forth in Defendants’ memorandum, Plaintiffs’ motion should be denied with respect to Hughes Hubbard.

Respectfully submitted, HUGHES HUBBARD & REED LLP

I hereby certify pursuant to 22 NYCRR § 1250.8(j) that the foregoing brief was prepared on a computer using Microsoft Word.

A proportionally spaced typeface was used, as follows: Name of typeface: Times New Roman Point size: 12 Line spacing: Double Word Count.

The total number of words in the brief, inclusive of point headings and footnotes and exclusive of pages containing the caption, table of contents, table of authorities, the signature block and this statement is 405 words.

At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2024

FRANK FUNDS TRUST, Individually and on Behalf of All Others Similarly Situated,

Upon the (i) Joint Affirmation of John Rizio-Hamilton and Daniella Quitt (“Moving Affirmation”); (ii) the Memorandum of Law In Support of Plaintiffs’ Motion for an Order to Show Cause to Provisionally Seal Documents Filed as Exhibits in Support of Plaintiffs’ Motion for an Order to Show Cause Compelling Defendants Goldman Sachs & Co. LLC and Morgan Stanley & Co. LLC to Produce Relevant Documents That Defendants Have Not Produced, Including Audio Recordings And Ethical Wall Logs (the “Motion); and (iii) upon all prior papers and proceedings in connection with the above-captioned action, and sufficient cause having been alleged, it is hereby: ORDERED that the Parties show cause before this Court at IAS Part 53 thereof, to be held in and for the County of New York, at the Courthouse, 60 Centre Street, Room 655, New York, NY 10017, at ________ on the __ day of __________, 2024, or as soon thereafter as counsel may be heard why an order should be entered sealing Exhibits A-H, M-Z, and AA-EE to the Motion, which were designated confidential by Defendants under paragraph 12(a) of the Stipulation and Order for the Production and Exchange of Confidential Information (NYSCEF Doc. No. 275) (the “Designated Confidential Documents’); ORDERED that pending the hearing on this Order to Show Cause, these designated confidential documents will remain temporarily under seal, accessible only to the parties, their counsel, and court personnel.

And proper cause being alleged, it is hereby: ORDERED that service of a copy of this Order and the papers upon which it is based upon Defendants by email on or before ____________, 2024 shall be deemed good and sufficient service thereof.

At IAS Part 53 of the Supreme Court of the State of New York, held in and for the County of New York, at the Courthouse located at 60 Centre Street, New York, New York on the___ day of __________, 2024

Index No. 654959/2021 The Honorable Andrew J. Borrok

FRANK FUNDS TRUST, Individually and On Behalf of All Others Similarly Situated,

Hon.

Andrew Borrok, J.S.C.