Cutit4:i 5vc0131AMAIAP WRidtillftitION& Iiiitcl PDf 6fcg 2 Holland 8c Knight 701 Brickell Avenue, Suite 3300 I Miami, FL 33131 IT IF 305.789.7799 Holland 8. Knight LLP I www.hklaw.com Christine N. Walz +1 305-789-7678 [email protected] Sanford L. Bohrer +1 305-789-7678 Sandy.Botver©hklaw.com March 19, 2020 Via ECF The Honorable Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: List of Decided Motions v. Maxwell, Case No. I5-c1-7433-LAP Dear Judge Preska: Both Plaintiff and Defendant Ghislaine Maxwell have asked for this Court's permission to file a List of Decided Motions under seal because the list contains information that is currently subject to the Sealing Order in this case. See Dkt. 132 and 133. "It is the clear law of this Circuit that civil docket sheets `enjoy a presumption of openness and that the public and the media possess a qualified First Amendment right to inspect them.'" Bernstein v. Bernstein Litowitz Berger & Grossmann LLP, No. I4-CV-6867 (VEC), 2016 WL 1071107, at •6 (S.D.N.Y. Mar. 18, 2016), ard, 814 F.3d 132 (2d Cir. 2016) (disclosing docket sheets after finding there are no "compelling private interests favoring sealing"). Where a presumption of the highest weight exists, "[tihe Court is required to order disclosure absent compelling reasons to deny access and even then must employ the least restrictive possible means of doing so." United States v. All Funds on Deposit at Wells Fargo Bank in San Francisco, California, in Account No. 7986104185, 643 F. Supp. 2d 577, 585 (S.D.N.Y. 2009Xemphasis added). Interveners therefore respectfully request that the List of Decided Motions be filed publicly. It is unclear to Intervenors what information in the title of any decided motions could be properly sealed. However, if such information exists, a redacted version of the list or a version of EFTA02781624