Case 1:15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 1 of 7 Haddon, HADDON N N and , PC Ty Gee ISO East 10th Avenue Denver. Colorado 80203 PH 303.831.7344 EX 303.832.2628 www.hmflow.com tgeeirShmllaw.com December 5, 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 Letter Brief re Materials That Should Remain Sealed or Redacted Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: Paragraph 1 of the Court's October 28 Order (Doc.998) required the parties to identify motions decided by the Court and related papers that were sealed or redacted ("Sealed Materials"). Paragraphs 3 and 5 required that any party contending a Sealed Material should remain sealed or redacted submit a letter brief providing the reason each such material should remain sealed or redacted. On November 19 the Court said the proponent of continued sealing/redaction need only state the reason in summary fashion. Doc.I 011. The Court extended to December 5 the time for submitting reasons. The difficulty and complexity of the project. Before reaching the merits of sealing/redaction of the Sealed Materials we think it appropriate and necessary to address the complexity and difficulty of the project as well as its difficult-to-overstate importance to the lives of Ms. Maxwell and the non-parties. The volume of Sealed Materials is substantial. The Sealed Materials contain motions, responses, replies, surreplies, sur-surreplies, memoranda, correspondence, declarations, exhibits, notices, and orders. Depending whether the materials were filed under seal, each motion, response, etc., occupied a separate docket number. We estimate we reviewed more than 600 docketed materials, totaling more than 8,600 pages. This project could not be accomplished by scanning or speed-reading. For redacted materials, there were many documents where there was only a single item on a page was redacted, e.g.,