Case 1:15-cv-07433-LAP KRIEGER Document 1228 Filed 08/10/21 Page 1 of 4 & LEWIN LLP 500 Fah Avenue Ncx York. NY 10110 Telephone (212) 390-9550 www.KKLIIpxom August 10, 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: On behalf of non-party, John Doe, we write in response to Plaintiff's letter of August 5, 2021, see DE 1227. Our letter of August 4, 2021 suggested several proposals to help expedite the continued implementation of the Protocol and the particularized review contemplated for each non-party. It appears, however, that the non-parties received, and presumably relied upon, a protocol process that is different than the process now being implemented. Specifically, the August 4 letter noted: "To the extent Plaintiff and Defendant suggest that they are entitled to file further oppositions to the non-parties' objections, they are incorrect?' DE 1226 at 2. In support of this, we cited Section 2(d) of the Protocol: "Within 7 days of service of any Non-Party Objection and accompanying memorandum, if any, the Original Parties may file an opposition stating the reasons why any Sealed Item should be unsealed." DE 1108, at 3. That same paragraph further provides the "objecting Non-Party may file a reply in support of its objections within 7 days of service of the Original Parties' opposition." Id. This language is contained in the version of the Protocol which we understand was mailed to all Does. See DEs 1115-16. Subsequent to the filing of our letter, we were directed to the Court's October 20, 2020 Order, issued in the context of the Court's consideration of the Sealed Records pertaining to Does No. 1 and 2. See DE 1157. In that Order, the Court observed "that several other NonParty Does have already submitted Objections to unsealing" and, at Plaintiff's urging,' the Court ruled that "Piny opposition