UNITED STATES BANKRUPTCY COURT

SOUTHERN DISTRICT OF FLORIDA

MIAMI DIVISION

www.flsb.uscourts.gov

In re: 

Leonardo Rozenblum Trosman and 

Fabian Elias Rozenblum Gorel Chapter 15

Debtors in a Foreign Proceeding. Case No.: 21-18199-LMI

_________________________________/

EX PARTE MOTION FOR ENTRY OF ORDER 

APPROVING CONFIDENTIALITY AGREEMENT

Relief requested without a hearing

The Uruguayan Association of Experts (“AUPE”), represented by Daniel Germán and 

Gabriel Ferreira (“Foreign Representative”), the duly appointed liquidator of Leonardo 

Rozenblum Trosman and Fabian Elias Rozenblum Gorel (the “Debtors”), files this Motion for 

Entry of Order Approving Confidentiality Agreement (the “Motion”) between the Foreign 

Representative and The Bank of New York Mellon and BNY Mellon, N.A., (the “Disclosing 

Party”) and in support thereof states as follows:

1. On November 5, 2021, the Foreign Representative filed a subpoena for Rule 2004 

Examination [DE 26] to the Disclosing Party (the “Subpoena”), which Subpoena was served on 

the Disclosing Party on November 8, 2021.

2. The Foreign Representative and the Disclosing Party have reached an agreement 

with regard to production of confidential information sought by the Foreign Representative and 

responsive to the Subpoena. The terms of the agreement are memorialized in the Confidentiality 

Agreement (the “Agreement”) attached as Exhibit “1”. 

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3. The Agreement is designed to ensure the confidentiality of the documents to be 

produced by the Disclosing Party.

4. The Foreign Representative respectfully requests that the Court enter the Order 

Approving Confidentiality Agreement attached as Exhibit “2” to protect the confidentiality of the 

information the Disclosing Party seeks to produce.

WHEREFORE, the Foreign Representative respectfully requests the entry of the attached

Order Approving Confidentiality Agreement with respect to discovery obtained from the 

Disclosing Party.

Dated: January 14, 2022 Respectfully submitted,

SEQUOR LAW, P.A.

1111 Brickell Avenue, Suite 1250

Miami, Florida 33131

Telephone: (305) 372-8282 

Facsimile: (305) 372-8202

 By: /s/ Carolina Z. Goncalves

Edward H. Davis, Jr., FBN 704539

edavis@sequorlaw.com

Carolina Z. Goncalves, FBN 124570

cgoncalves@sequorlaw.com

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was filed via electronic 

filing using the CM/ECF system with the Clerk of the Court which sent e-mail notification of such 

filing to all CM/ECF participants in this case and via regular US mail to all participants who are 

not on the list to receive e-mail notice/service for this case as indicated on the service list on 

January 14, 2022.

By: /s/ Carolina Z. Goncalves

Carolina Z. Goncalves 

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SERVICE LIST

Electronic Mail Notice List

The following is the list of parties who are currently on the list to receive email notice/service for 

this case. 

 Edward H. Davis,Jr., Esq. edavis@sequorlaw.com; msanchez@sequorlaw.com

 Carolina Z. Goncalves, Esq. cgoncalves@sequorlaw.com; msanchez@sequorlaw.com

 Office of the US Trustee USTPRegion21.MM.ECF@usdoj.gov

Manual Notice List

 (No manual recipients)

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