Case 1:15-cv-07433-LAP BSF Document 1052 Filed 04/30/20 Page 1 of 4 BOIES SCHILLER FLEXNER April 30, 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, The Original Parties jointly write to seek clarification of the following parts of the Protocol for Unsealing Decided Motions, ECF No. 1044: • Paragraph 2: "[T]he Court will conduct an individualized review of several Sealed Items at a time, thereby allowing the review to proceed on a rolling basis and in a manageable fashion. The Court will review sealed items based on the Non-Party mentioned in the Sealed Materials. For example, for Doe #1, the Court would review each Sealed Item that mentions Doe #1, and would do the same for Does #2, #3, etc. This will allow the Court more easily to manage and review any objections from Non-Parties." • Paragraph 2(b): "As soon as practicable after the Notification the Original Parties shall confer and shall use their best efforts to cause each Non-Party mentioned in the Sealed Materials to be considered to be served confidentially with the Non-Party Notice." • Paragraph 2(j): "After objections, responses and replies have been submitted, and any evidentiary hearing held, the Court will determine whether each Sealed Item shall be (1) unsealed in its entirety, (2) unsealed in redacted form, or (3) kept under seal." The Original Parties disagree as to whether they should notify all Non-Parties mentioned in the first five motions that the Court has selected for review (Docket Entries 143, 164, 172, 199, and 230 (the "First Five Motions"), see ECF No. 1047), or only J. Doe 1 and J. Doe 2. The Original Parties also disagree as to whether, when the Court makes a ruling pursuant to Paragraph 2(j), it will be ruling on whether an entire document should be unsealed, or ruling on whether certain portions of a do