Callast:1566‘40ZOBIBIIMAP BSF BOIES SCHILLER FLEXNER Sigrid S. McCauley Telephone: (954) 356-0011 Email: 5mccawlevabsflly cons 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: FRIEctIAREIESB Flitypi &Id 1 October 26, 2023 Doe 107 shall, by November 22, 2023, submit to the Court for in camera review an affidavit supporting her assertion that she faces a risk of physical harm in her country of residence and providing detail concerning the hate mail she received. Doe 107's counsel may provide additional factual support for Doe 107's contention that unsealing the relevant records would put her at risk of physical harm by November 22, 2023 as well. v. Maxwell, SO ORDERED. Case No. 15-cv-7433-LAP 0,/-tea,660 Dear Judge Preska, ›idzeigt 10/27/2023 The Parties, the Miami Herald, and Doe 107 write in response to the Court's August 24, 2023, order. ECF No. 1306. Based on counsel's representations concerning Doe 107's safety in her current country. the Parties and the Miami Herald consent to redacting Doe 107's name and any personally identifying information in the docket entries that the Court previously ordered unsealed. and the Miami Herald's consent to such redactions is based on circumstances specific to Doe 107 and does not extend to other purported victims living in countries without the same risks of physical harm. The Parties therefore respectfidly request the Court's permission to maintain the redactions to Doe 107's name and personally identifying information. Sincerely, /s/ Sitirid S. McCawlev Sigrid S. McCawley Counsel for Plaintiff /s/ Richard Levitt Richard Levitt Counsel for Doe 107 /s/ Laura Menninaer Laura Metufinger Counsel for Defendant /s/ Christine N. Waltz Christine N. Waltz Counsel for Miami Herald cc: Counsel of Record (via ECF) BOIES SCHILLER FLEXNER LLP 401 Eost Los Olos Boulevard. Suite 1200. Fort Lauderdale. FL 333011 (t) 95