Case 1:15-cv-07433-LAP Document 1207 Filed 02/05/21 Page 1 of 1 Haddon. and Pc Laura A. Menninger I50 East 10th Avenue Denver. Colorado 80203 PH 3O3.831.7364 rx 303.832.2628 vAqw.hmllaw.com [email protected] HADDON N N February 5, 2021 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 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 Memorandum of Law in Support of Objections to Unsealing Sealed Materials Related to DEs 345, 356, 362, 370, 422, 468 & 640 and to file a redacted Exhibit A 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 A 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 versions of the Memorandum and Exhibit A publicly on ECF and seeks leave only to file the unredacted Memorandum and Exhibit A under seal. Respectfully submitted, Laura A. Menninger 12----6 7 CC: Counsel of Record via ECF EFTA02785838