Case 1:15-cv-07433-LAP Document 1083 Filed 07/30/20 Page 1 of 3 Haddon, it I) I, II S and S P.0 Laura A. MennInger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmflaw.com [email protected] July 30, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Jul 23 and July 29, 2020 Orders (Does. 1077, 1079) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: This Court Ordered on July 23, 2020 (Doc. 1077) that the parties redact from those pleadings to be unsealed three categories: 1) "personal identifying information as to any person mentioned in the documents," 2) "the names of nonparties other than Does 1 and 2," and 3) "other portions related to such nonparties' specific conduct." The rationale for redacting categories 2 and 3, implicit in the Court's Order and Protocol for Unsealing Decided Motions, was to afford each Nonparty the opportunity for notice and the chance to be heard prior to unsealing materials that implicate their privacy rights. (Doc. 1044).' Nonparties on the list include (a) persons who produced or answered discovery based on the understanding that such discovery would be subject to the Protective Order, (b) persons who are identified as allegedly having engaged in sex acts with Plaintiff or other alleged victims, or facilitated such acts, (c) persons whose "intimate, sexual, or private conduct is described in the Sealed Materials," and (d) persons who allegedly have been victimized. Id. at 1. The parties conferred on July 29, 2020. Plaintiff, after making some changes to address these concerns, plaintiff nevertheless submitted to the Court late on July 29 numerous proposed redactions which disregard the Court's Order to redact "names of nonparties" and "nonparties' specific conduct." Plaintiff proposes to unseal significant portions of the testimony which would not only identify the Nonparty at issue, but also