Case 1:15-cv-07433-LAP BSF Document 1099 Filed 08/10/20 Page 1 of 4 I BOIES SCHILLER FLEXNER Sigrid S. McCawley Telephone: (954) 356-0011 Email: smccawlevdasfiln.com August 10, 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, Plaintiff writes pursuant to the Court's August 3, 2020 order directing the parties to confer and report suggestions for streamlining the unsealing process and a proposed next set of docket entries to be reviewed for potential unsealing. Dkt. 1096. As to streamlining the process, the parties have agreed upon the following changes to the Protocol: First, to speed up the unsealing process and to minimize the number of Non-Party names that need to be redacted from future materials that are unsealed, the parties will send the Non-Party Notice to all remaining Non-Parties as soon as practicable. Once all Non-Parties are noticed, the Court and the parties will better understand exactly how many Non-Parties intend to participate in the unsealing process. The number of Non-Parties who request excerpts will help inform the Court's decision as to how to proceed with the Protocol going forward. Having a list of Non-Parties who have not requested Excerpts (and who therefore do not intend to object to unsealing) will also be exceedingly helpful to the Original Parties tasked with redacting the names of Non-Parties who have not yet had the opportunity to object to unsealing. For example, going forward, the Original Parties would need to redact fewer names in documents that are ordered unsealed because they would have a list of Non-Parties who have no objection to their names being unsealed. Plaintiff suggests that the Original Parties serve the Non-Party Notice on all Non-Parties within 7 days, and that the Original Parties file letters with the Court 21 days thereafter advising the