Case 1:15-cv-07433-LAP Document 1037 Filed 03/26/20 Page 1 of 2 Haddon. HADDON A N N and rc Laura A. Menninger I50 East 10th Avenue Denver. Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmllow.com [email protected] March 26, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: March 19, 2020 Order (Doc. 1034) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: Pursuant to this Court's Order of March 19, 2020 (Doc. 1034) at 3, attached please find Ms. Maxwell's proposed changes to the Court's proposed revisions to the Protocol, Notice to Non-Parties, the Non-Party Request for Excerpts, and the Non-Party Form Objection. Counsel conferred with plaintiff's counsel concerning these proposed revisions, who object for reasons that they intend to explain to the Court by separate letter. Ms. Maxwell believes the proposed changes, as reflected in the attached redlined version, are appropriate for the following reasons: 2(d): One or both of the Original Parties may want to oppose a Non-Party Objection by arguing for un-sealing. Any argument by an Original Party for sealing would be covered by 2(f) and not in opposition to the Non-Party. 2(f): The Court in its Order at 1 5 recognized the right of reply for both objecting and non-objecting parties. The change to this paragraph was intended to reflect that right. 3(e): The Non-Parties are advised in their Objection to Un-Sealing at 12 that they "understand this Objection will be filed under seal and I will not be identified in any court filing." Ms. Maxwell remains concerned that Non-Parties will be reluctant to participate in this process if their objection will itself become publicized and also believes that despite best redaction efforts and pseudonym efforts, any objections may reveal the identity of its author. For those reasons, Ms. Maxwell respectfully requests that the Non-Party Objections themselves be maintain