Case 1:15-cv-07433-LAP Document 1010 Filed 11/18/19 Page 1 of 3 Haddon. and PC Ty Gee D A DDON N 150 East 1 Oth Avenue Denver, Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hmflaw.com tgee4hrnflaw.corn November 18, 2019 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Defendant Maxwell's Request for Clarification and More Time to Address Paragraphs 2, 3, and 5 of the Court's October 28, 2019 Order (Doc.998) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: Paragraphs 2 and 3 of your October 28 Order require that the parties' counsel conduct a review of the sealed and redacted materials, confer and inform the Court by letter about the identity of non-parties identified in the material, and confer and inform the Court by letter of any material in the already-decided motions that should remain sealed and the reason the material should remain sealed. Paragraph 5 provides that to the extent the parties disagree on what material in the already-decided motions should remain sealed, the party favoring sealing shall submit its letter by November 19. Plaintiff reversed her position about the protective order some time ago and now takes the position that all the material should be unsealed. One does not need to be clairvoyant to accurately predict that Plaintiff will disagree with any request to maintain the sealed documents "as is," making any conferral largely futile and placing the burden of identifying the information that should remain sealed and the reasons for continued sealing exclusively with the Defendant. We request clarification of the Order. Providing the "reason" a particular document should remain sealed can be accomplished in summary fashion, e.g., "Doc. should remain sealed because it implicates Ms. Maxwell's privacy interests." Alternatively providing the reason can be accomplished through briefing, with evidentiary support. Since the Court is requesting