Case 1:15-cv-07433-LAP Document 1025 Filed 01/30/20 Page 1 of 17 Haddon. II A I) I) 0 N N and Pc Ty Gee 150 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 EX 303.832.2628 www.hrnflow.com tgeeghrnflaw.corn January 30, 2020 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 Submitting Materials Relating to Protocol and Non-Party Notice v. Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: We submit with this letter four documents for the Court's review and approval: • [Proposed] Order and Protocol for Unsealing Decided Motions ("Order and Protocol"); • Notice to Non-Parties of Possible Unsealing of Sealed Documents ("Non-Party Notice"); • Form - Non-Party's Request for Excerpts of Sealed Documents and Acknowledgment of Court Order and Protocol Governing the Excerpts ("NonParty Request"); • Form - Non-Party's Objection to Unsealing ("Non-Party Objection"). The originalaties have conferred between themselves and with counsel for Intervenors and Miami Herald and for Doe (collectively, "Seal Participants"). All the Seal Participants agree on the form of the last three bulleted documents. There are a few disagreements relating to the language of the Order and Protocol that the Seal Participants request that the Court resolve. EFTA02781520