Case 1:15-cv-07433-LAP Document 1321 Filed 01/04/24 Page 1 of 2 Holland & Knight 31 West 52nd Street I New York, NY 10019 IT IF 212.385.9010 Holland & Knight LLP I vwvw.hklaw.com Christine N. Walz +1 212-513-3368 [email protected] January 4, 2024 Via ECF The Honorable Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: LETTER MOTION TO UNSEAL DOCKET ENTRY 1026-3 v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska: and Miami Herald Media Company respectfully submit this Intervenors Julie letter-motion to unseal (in part) Docket Entry 1026-3 to clarify how the assigned J. Doe pseudonyms line up with the disclosed individuals in each of the unsealed docket entries, as well as the Court's reasoning associated with the same. Docket Entry 1026-3 was submitted by counsel for and Maxwell as part of the unsealing protocol in this matter. It lists all the non-parties listed in any of the originally sealed documents and was used by the Court to manage the unsealing process and make its determinations about what information was to be unsealed. It is, therefore, a judicial document subject to the public right of access. See United States v. Amodeo, 44 F.3d 141, 145 (2d Cir. 1995) (a filed document is a judicial document if it is "relevant to the performance of the judicial function and useful in the judicial process."). Now that the Court has made all its rulings on the unsealing of documents (and as part of that decision, is releasing the names of most non-parties), this document should be unsealed in accordance with the Court's decisions. As a practical matter, the unsealing is garnering a significant amount of media coverage — by Intervenors, other news organizations, and commentators on social media. Without this list, Intervenors and the public are puzzling together the Court's ruling with each of the unsealed documents to match the identities of each of the third p