Case 1:15-cv-07433-LAP BSF Document 1038 Filed 03/26/20 Page 1 of 2 I BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 356-0011 Email: [email protected] March 26, 2020 VIA ECF The Honorable 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, Pursuant to the Court's March 19, 2020 Order (Dkt. 1034), Plaintiffs counsel and Defendant's counsel have conferred about the Court's proposed Protocol. Plaintiff agrees to the Court's Protocol as written, including the Court's proposal to review documents by Non-Party in the order that the Non-Parties are listed on the Non-Party list. Defendant has proposed a number of changes to the Court's proposed revisions to the Protocol, however, to which Plaintiff objects as follows. First, Defendant proposes that paragraph 2(f) of the Protocol, which addresses the situation in which a Non-Party does not object to a document's unsealing, be changed to provide the Original Party objecting to unsealing (i.e., Defendant) with an automatic right to file a reply brief. But because this paragraph deals with the situation in which a Non-Party has not objected to unsealing, an automatic right to a reply brief would allow Defendant to file two briefs in support of keeping a document sealed and Plaintiff to file only one brief in support of unsealing. In the event that a Non-Party does not file an objection, and only the Original Parties am briefing the issue of whether a document should be unsealed, each Original Party should be permitted to file one brief unless the Court otherwise orders. Second, Defendant proposes that paragraph 3(e) be deleted in its entirety. Plaintiff disagrees. This paragraph allows the Court to determine what redactions are appropriate, in consultation with the parties, before filing Non-Parties' objections on the docket. To the extent an objection reveals identi