Case 1:15-cv-07433-LAP Document 1165 Filed 12/01/20 Page 1 of 2 Haddon. II and Pc Laura A. Menninger I50 East 10th Avenue A l/ N Denver. Colorado 80203 PH 303.831.7364 rx 303.832.2628 www.hmllow.com [email protected] December 1, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Motion to File Under Seal and Request for Additional 34/ Page of Briefing v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: This is a letter motion seeking leave to permit Ms. Maxwell to file a redacted Reply Memorandum of Law in Support of Objections to Unsealing Sealed Materials Related to DEs 231, 279, 315, 320 & 335 and to file under seal Exhibit E thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. Doc. # 62 at 4. The Memorandum of Law and Exhibit E contain information deemed CONFIDENTIAL by the parties pursuant to the Protective Order. References to and discussion of specific CONFIDENTIAL materials are necessary to support Ms. Maxwell's request that these materials remain under seal. Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and seeks leave only to file the unredacted version and Exhibit E under seal. Ms. Maxwell additionally requests, pursuant to paragraph 2(g) of the Protocol (DE 1108) that she be permitted an additional' of a page for her Reply. The Protocol permits applications for an extension of the page limits of any memorandum on an ad hoc basis. In her Reply, Ms. Maxwell needed to address a significant number of legal and factual issues raised by plaintiff in her Objections, includin clarifying the record regarding Non-Party Notices, the effect of