Case 1:15-cv-07433-LAP KRIEGER Document 1040 Filed 03/30/20 Page 1 of 1 & LEWIN LLP Tckphonv: (212! 30)-0550 wn.1.1:111(rvoni 500 Fifth Avenue New York. NY 10110 March 30, 2020 By ECF The Honorable Loretta A. Preska United States District Judge Southern District of New York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: v. Maxwell, 15 Civ. 07433 (LAP) Dear Judge Preska: We write on behalf of a non-party, John Doe, in response to the parties' submissions, dated March 26, 2020 (DE 1037; DE 1038), and in advance of the conference scheduled for March 31, 2020, see Order, dated Mar. 30, 2020, DE 1039, at l; those submissions regarded additional changes to the protocol for notification of non-parties of the potential unsealing of certain filed documents. Non-party John Doe concurs with the modifications proposed by the defendant, for the reasons set forth in her submissions. See Defendant's Letter dated Mar. 26, 2020, DE 1037, at 1-2. We respectfully propose one additional change to the protocol. In light of the extraordinary challenges, logistical and otherwise, presented by the ongoing coronavirus/COVID-I9 pandemic — as have been formally recognized by this District, see, e.g., In Re: Coronavirus/COVID-19, 20-mc-00173 (S.D.N.Y.) — we submit that it is necessary and appropriate to provide at least non-parties with additional accommodations to meet the deadlines and requirements presently provided for under the protocol. To that end, we propose the following: that paragraph 2(c) be revised to provide 30 days (rather than 14 days) for non-parties to submit a request for excerpts; that the first sentence of paragraph 2(f) be revised to reflect the same 30-day deadline; and that paragraph 2(d) be similarly revised to provide 30 days (rather than 14 days) for non-parties to submit an objection to unsealing/unredacting and 14 days (rather than 7 days) for non-parties to file a reply in support of their position. Respectful) Submitted, KRIEGER & LEWIN LLP By: