Case 1:15-cv-07433-LAP KRIEGER Document 1250 Filed 04/18/22 Page 1 of 7 & LEWIN LLP 500 Fifth Avenue New Yogic, NY 10110 'Felt-phone: (212) 390-9550 wv.KKIllpeom April 18, 2022 ECF The Honorable Loretta A. Preska United States District Judge Southern District ofNew York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: v. Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We write res.. 11y on behalf of non-party John Doe in response to the Memorandum of Intervenors Julie and The Miami Herald Media Co. (collectively, "Intervenors"). See DE 1248. The Intervenors' requests to unseal should be denied. A. Intervenors' First Proposition of Law: For minor victims of sexual abuse, "redactions should be applied sparingly to shield only information that would identify those who have not already been publicly identified." DE 1248, at 2. The Reality: Courts routinely seal records concerning underage victims — well beyond replacing their names with initials — and victims do not forego their rights to privacy merely because they have played a role in a civil or criminal case against perpetrators. As an initial matter, Intervenors seek to unseal documents concerning the alleged sexual abuse of minors over the express wishes of those victims. Yet, by relying on inapposite case law and urging legal propositions that are, in fact, contrary to Second Circuit precedent, Intervenors' brief only underscores that the Court should resist allowing its records to result in the publishing of "the painful and sometimes disgusting details of a ... case," that "promote public scandal." Nixon v. Warner Commc 'us, Inc., 435 U.S. 589, 598 (1978) (internal quotation marks omitted). In support of their claim that "there is no basis" to continue respecting the privacy rights of an "already ... disclosed" victim's identity and circumstances, id. at 3, Intervenors point to v. Colvin, 2015 WL 4240721 (S.D.N.Y. July 13, 2015), a habeas case wherein the government — not an abuse victim — fil