Case 1:15-cv-07433-LAP BSr Document 1026 Filed 01/30/20 Page 1 of 3 F SCHILLER FLEXNER Telephone: (954) 356-0011 Email: [email protected] January 30, 2020 VIA ECF AND FACSIMILE The Honorable Judge Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska: Plaintiff writes to update the court on the progress of the parties' discussions regarding the unsealing protocol to be administered by the Court. The parties are in agreement as to the majority of the protocol's provisions, including the form Nonparty Notice, but have come to an impasse on a few key issues. The disagreements are reflected in Plaintiff's proposed protocol (Ex. A) and the attached redline comparing Plaintiff's proposed protocol with Defendant's proposed protocol (Ex. B). I. List of Decided Motions First, the opening paragraph of Defendant's proposed protocol states that this Court "approved" Defendant's list of decided motions (Dkt. 1007-1) as the list of motions to guide the unsealing process. That is not true. According to the transcript of the status conference before the Court on January 16, 2020, the Court directed the parties to use the format of Defendant's list of decided motions, but it did not "approve" the contents of Defendant's list. In fact, the Court's words were: "the reason I like this listing is because it lists the motion, the date it was filed, the related conference documents, the docket number of the order resolving the motion, and the date of the resolution and whether it is sealed or redacted. So, I would like to work off of this form if we could." Dkt. 1021 at 10:22-11:6. Plaintiff objects to using Defendant's list of decided motions because it excludes two motions that Judge Sweet decided from the bench. Those motions are: (1) Plaintiff's Motion to Compel Ghislaine Maxwell to Produce Data from Undisclosed Email Account and For a