Case 1:15-cv-07433-LAP Document 1042 Filed 03/31/20 Page 1 of 2 Holland 8c Knight 701 Brickell Avenue, Suite 3300 I Miami, FL 33131 IT IF 305.789.7799 Holland 8 Knight LLP l www.hklaw.com Christine N. Walz +1 305-789-7678 Sandy.Bohter©hklaw.com Sanford L. Bohrer +1 305-789-7678 Sandy.Bohrer©hklaw.00m March 31, 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 se to Dkt. Nos. 1037, 1038 ,140 v. Maxwell, Case No. 15-cv-7433-LAP Re: lo Dear Judge Preska: Intervenors Julie and Miami Herald Media Company write in response to the parties' letters dated March 26, 2020 (Dkt. Nos. 1037, 1038), and in advance of the conference scheduled for March 31, 2020, pursuant to this Court's Order dated March 30, 2020 (Dkt. No. 1039). Specifically, Intervenors respond to: • Ms. Maxwell's mischaracterization of the media's role and interest in this case; • Ms. Maxwell's request that Non-Party Objections be made under seal; and • J.Doe's proposed extension of the time frames set forth in the protocol. First, Ms. Maxwell's attack on Intervenors' reporting on this case of significant public interest is wholly unwarranted, and her positions demonstrate her interest in continues to hide from public scrutiny that which has already been sealed for far too long. She further fundamentally mischaracterizes the role of the media in seeking access to court records: The media are not distinguishable from the public; they are the surrogates for the public. See Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555, 573, 100 S. Ct. 2814, 2825, 65 L. Ed. 2d 973 (1980)("Instead of acquiring information about trials by firsthand observation or by word of mouth from those who attended, people now acquire it chiefly through the print and electronic media ... validat[ing] the media claim of functioning as surrogates for the public."). Thus, a request by the media for access EFTA02