Case 1:15-cv-07433-LAP BSF Document 1013 Filed 12/12/19 Page 1 of 5 BOIES SCHILLER FLEXNER Telephone: (954) 356-001I Email: [email protected] December 12, 2019 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. afaxw Case No. Dear Judge Pre s : Plaintiff responds to Defendant Ghislaine Maxwell's sealed letter in response to Paragraph 3 of the Court's October 28, 2019, Order. See Dkt. 998.1 Plaintiff opposes Maxwell's broad and categorical attempt to keep virtually all of the motion papers in this matter, which are judicial documents afforded a presumption of public access, shielded from the public. As set forth below, Maxwell fails to meet her burden of establishing that any of the documents should remain under seal. First, the first three pages of Maxwell's submission, which (I) detail "the difficulty and complexity" of complying with the Court's instructions to provide reasons for maintaining under seal judicial documents to which the public has a presumptive right to access, and (2) describe the task's "difficult-to-overstate importance to the lives of Ms. Maxwell and the non-parties," serve no purpose. See Del.'s Dec. 5 Ltr. at 1-3. "Difficulty" is no reason to deny the public access to documents to which it is entitled under law. Maxwell is the party who seeks to protect these judicial documents from public scrutiny. The burden of providing specific reasons to do so therefore falls on Maxwell, not Plaintiff or the Court. The 'media's' interest in this case" is also not a reason to keep judicial documents sealed. Id. at 3. To the contrary, it demonstrates the public's strong interest in these materials, for which a strong presumption of access applies. Maxwell's letter suggests that the Second Circuit's unsealing of 2,000 pages of sealed and redacted summary judgment materials caused increased media interest in Maxwell. To be clear, Maxwel