Case 1:15-cv-07433-LAP KRIEGER Document 1226 Filed 08/04/21 Page 1 of 4 & LEWIN LLP 500 Fifth Avenue New York, NY 10110 Tekphonee (212) 390-9550 www-KKI-11p.com August 4, 2021 By ECF The Honorable Loretta A. Preska United States District Judge Southern District of New York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: v. Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We are writing on behalf of a non-party, John Doe, in response to the letters filed by the parties in the above-referenced case offering competing proposals for streamlining the unsealing process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224. We write to express our views regarding the parties' respective submissions, as well as that offered by the Miami Herald. See DE 1225. As directed by the Second Circuit, this Court has made notable progress in its individualized review of the Sealed Materials. We appreciate that this is a substantial undertaking. However, we submit the time consumed by this review is not caused by the process prudently outlined under the Protocol; rather, it is a consequence of the more than one hundred non-parties implicated in the Sealed Records, the diversity and significance of their respective interests, and the sheer volume of materials contained within the Sealed Records. See DE at 1224, at 5. Plaintiff and Defendant each generously designated materials as confidential under the Protective Order, and the process of determining what excerpts to unseal from such a voluminous record is necessarily challenging, particularly given the significant privacy interests implicated. The Protocol ordered by the Court, after substantial input from the parties, is achieving its desired purpose of: (a) attempting to provide notice and an opportunity to object to non-parties to the release of Sealed Materials; (b) establishing a fixed schedule and procedure for both parties and non-parties to promptly state their respective positions on