Case 1:15-cv-07433-LAP KRIEGER Document 1019 Filed 01/15/20 Page 1 of 4 & LEWIN LLP 500 Filth Avenue New York. NY 10110 'telephone (212) 390-9550 novw.KKIllpeom January 15, 2020 By ECF The Honorable Loretta A. Preska United States District Judge Southern District ofNew York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: v. Maxwell, 15 Civ. 07433 (LAP) Dear Judge Preska: We write on behalf of an anonymous non-party, John Doe, in advance of the conference in the above-referenced matter scheduled for tomorrow. The purpose of this conference, as set forth by the Court, is to "discuss next steps that will enable the Court to conduct an individualized review of relevant documents" for potential unsealing. Order, dated Dec. 16, 2019 (DE 1016), at 1. The Court has further explained that those next steps include — in addition to evaluating the weight of any presumption of public access that applies to judicial documents — identifying and assessing "any countervailing factors that function to limit the weight of the presumption of public access." Id. And the Court has specifically explained that, as part of evaluating those countervailing factors, it intends to "address notification of third parties named in the documents." Id. at 2. We write to renew our request that, as the Court establishes an individualized review process, it consider the protocol we initially proposed in our letter to the Court dated September 3, 2019 (DE 980). We have appended a revised proposed protocol hereto, which seeks to incorporate the progress made by the Court and parties since then. Respectful) Submitted, KRIEGER & LEWIN LLP .44.449. By: Ni 1olas J. Le Paul M. Kriege Encl. cc (by ECF): All counsel of record EFTA02781473