H A D D O N MORGAN FOREMAN August 17, 2020 VIA EMAIL The Honorable Alison J. Nathan United States District Court Southern District of New York 40 Foley Square New York, NY 10007 Re: Request to Modify Protective Order (UNDER SEAL)' United States v. Ghislaine Maxwell, 20 Cr. 330 (MN) Haddon, Morgan and Foreman, t.c Jeffrey Paglloca 150 East 10th Avenue Denver, Colorado 80203 rti 303.831.7364 FX 303.832.2628 www.hmflaw.com jpaglucaahmflaw.com Dear Judge Nathan, Defendant Ghislaine Maxwell, pursuant to paragraph 18 of this Court's Protective Order (Doc. # 36), requests that the Court enter an Order allowing her to refer to and file under seal in Giuffre v. Maxwell, 15-cv-5433 (LAP), and a related Second Circuit appeal, Giuffre v. Maxwell, No. 20- 2413 (the "Other Matters"), certain discovery materials produced by the government on August 5, 2020. She also seeks to refer to (but not file) discovery materials produced by the government on August 13, 2020, specifically the 90,000 pages of documents received from Boies Schiller & Flexner, which appears to include their entire civil file from the Giuffre case. 2 Disclosure to the judicial officers in the Other Matters is necessary for fair determination of important issues impacting the privacy and due process rights of Ms. Maxwell and other third parties. The ten discrete items to be filed ("the Material") are not confidential and disclosure confined to the Honorable Loretta Preska and the Second Circuit Court of Appeals, under seal, ' Ms. Maxwell seeks leave to file this Letter Motion under seal because it relates and refers to discovery materials deemed Confidential under the terms of the Protective Order in this case. 'Counsel for Ms. Maxwell have not conducted a document by document comparison of the 90,000 pages with documents in their possession related to the Maxwell civil matters but presumes they are the same. Paragraph 16 of the Protective Order in this case exempts information ob