Case 1:15-cv-07433-LAP Document 1204 Filed 01/29/21 Page 1 of 3 Haddon. HADDON N N and r.c Laura A. MenaInger 150 East 10th Avenue Denver. Colorado EO203 PH 303.831.7364 rx 303.832.2628 www.hrnflaw.com [email protected] January 29, 2021 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Limited Motion to Reconsider Proposed Redactions of Ms. Maxwell's July 2016 Deposition Transcript v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: I write in reply to the letters filed by plaintiff and the Miami Herald in opposition to Ms. Maxwell's limited motion for reconsideration. As explained below, neither letter appreciates the stakes, and both misunderstand the basis for Ms. Maxwell's narrow and targeted request of this Court. For her part, plaintiff's letter is patently inconsistent. The stakes first. "No right ranks higher than the right of the accused to a fair trial." Press-Enter. Co. v. Superior Court, 464 U.S. 501, 508 (1984). Neither plaintiff nor the Herald appreciate this, and both fail to acknowledge that the balance of interests weighs even more strongly in favor of Ms. Maxwell when, as here, the presumption of access to a judicial document is at its lowest, amounting to "little more than a prediction of public access absent a countervailing reason." v. Maxwell, 929 F.3d 41, 49-50 (2d Cir. 201filiting United States v. Amodeo, 71 F.3d 1044, 1050 (2d Cir. 1995) ("Amodeo 11")). The court expressly acknowledged the right of an accused as a "countervailing interest" worthy of overcoming any presumption of access. Id.at 47 n. 13. ("Examples of such countervailing values may include, depending on the circumstances, preserving 'the right of an accused to fundamental fairness in the jury selection process ..."') (quoting Press-Enter. Co., supra, 464 U.S. at 510)). Ms. Maxwell's arguments next. According to the Herald, Ms. Maxwell seeks to "suppress" evidence of perjury. Dk