Case 1:15-cv-07433-LAP Document 1225 Filed 07/30/21 Page 1 of 2 Holland & Knight 31 West 52nd Street I New York. NY 10019 I T 212.513.32001 F 212.385.9010 Holland 8 Knight LLP I wAnv.hklaw.corn Christine N. Watz +1 212-513-3368 Christine.Watz©Ndaw.com Sanford L. Batter +1 305-789-7678 Sandy.Bohren§hklaw.com July 30, 2021 Via ECF The Honorable Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: INTERVENORS' LETTER REGARDING REVISIONS TO THE UNSEALING PROTOCOL it. Maxwell, Case No. 15-ev-7433-LAP Dear Judge Preska: Intervenors Julie and Miami Herald Media Co. respectfully submit this letter in response to the Court's inquiry at the July I, 2021 hearing regarding ways to streamline the unsealing protocol moving forward, and in response to Maxwell's letter (Dkt. 1224). Intervenors ask that the Court adopt the proposal submitted by . (See Dkt. 1224.) Reviewing all of the documents referencing objecting Does at once will significantly reduce the number of times a single document is reviewed, redacted (if warranted), and released. This will streamline the process and allow for more timely and meaningful access to these records. Ms. Maxwell's submission argues that this proposed process is too onerous while her counsel prepare for her criminal trial, but her proposal (and the status quo) require far more duplication and therefore more work, absorbing snore of her counsel's time. If the Does continue to be split into multiple groups with multiple rounds of reviews, as Ms. Maxwell proposes, then a single document such as initial disclosures or a witness list will continue to resurface in every round, only to have redactions removed from a few names each time, thereby multiplying the review. Instead, if all objecting Does are considered at the same time, along with any non- Atlanta I Austin I Boston I Charlotte I Chicago I Dallas I Denver I Fort Lauderdale I Houston I Jacksonv