Case 1:15-cv-07433-LAP BOI ES, SCHI Document 171 Filed 05/27/16 LLER FLEXNER 401 EAST LAS OLAS BOULEVARD • SUITE 200* FORT LA1J:.:L • & Page 1 of 1 L LP LE. FL 3330i • 2211 • PH 954 356 001 • FAX 954 356 0022 Sigrid S. McCawley, Esq. Email: smccawleviabsilla.com May 27, 2016 Via CM/ECF Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: v. Maxwell, Case no. 15-cv-07433-RWS — Regarding Protective Order Dear Judge Sweet: This is a letter motion to file Motion to Exceed Presumptive Ten Deposition Limit in Federal Rule Civil Procedure 30(AX2Xa)(ii) and certain accompanying exhibits under seal pursuant to this Court's Protective Order (DE 62). The Protective Order states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. See Protective Order (DE 62) signed on March 17, 2016, at . 4. Defendant has designated Defendant's entire deposition testimony as confidential. takes no position at this time on whether Defendant's designations are proper. Because of the Protective Order, however, believes that she cannot presently produce or reference such documents in public court filings. has designated a third-party witness deposition as confidential. As MI Motion contains material that the parties have designated as confidential, she seeks leave to file the Non-Redacted Motion and certain related exhibits under seal. Respectfully submitted, cc: Laura Menninger, via CM/ECF Jeffrey Pagliuca, via CM/ECF WWW.ESSFLLP.COM EFTA02797569