Case 1:15-cv-07433-LAP BSF Document 1227 Filed 08/05/21 Page 1 of 2 BOIES SCHILLER FLEXNER August 5, 2021 VIA ECF The Honorable Loretta A. Preska District Court Judge United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: v. Maxwell. Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes in response to John Doe's August 4, 2021, letter to the Court to correct certain inaccuracies and to address certain criticisms of the Original Parties. First, Doe criticizes the Original Parties' compliance with the Court's unsealing orders and directives to redact the names of non-parties whose interests the Court has not yet considered, which has involved an immense amount of resources. ECF No. 1226 at 2. According to Doe, the Original Parties must not only scour each document that the Court orders unsealed to identify all non-party names and identifying information for redaction, but must also determine what other information could potentially provide clues as to the identities of the non-parties. This suggestion is entirely unworkable, as it would involve weeks of conferral between the Original Parties. Further, Doe's suggestion must be viewed against the legal backdrop of these proceedings — that information filed on a docket enjoys a presumption ofpublic access, not a presumption of closure. The Original Parties have wholly complied with the Court's directive to redact the "names and identifying information of nonparty Does." Tr. of July 1, 2021 Ruling at 7:9-14. As the Court explained during its most recent ruling, if there is identifying information about Doe himself that he contends must be redacted, he may request that relief under seal. Id. at 15:15-25. But he has not done so, apparently unwilling to even disclose his identity under seal. Second, Doe appears to misunderstand the current status of the unsealing process in contending that 'The Court should continue its process of reviewing items in the order they app