Case 1:15-cv-07433-LAP BOIES, 401 EAST LA :L•%:_: ico., Document 289 SCHILLER & Page 1 of 1 Filed 07/18/16 FLEXNER " R"' • SJ1TE 1200 • FORT LAUDERDALE FL 33301-22 • PH 954 356.00 LLP • I AX 954.356 0022 Maeda, Esq. Email: mschultz©bsffla.com July 18, 2016 Via CM/F,CF 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 — Retarding Protective Order Dear Judge Sweet, This is a letter motion to file Response in Opposition to Defendant's improper letter motion to strike Plaintiff Motion for an Adverse Inference Instruction Pursuant to Rule 37(B), (E), and (F), Fed. R. Civ. P., 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 accompanie3d 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 p. 4. Numerous materials have been marked as confidential in this case. As Motion for an Adverse Inference Instruction Pursuant to Rule 37(b), (e), and (0, Fed. R. Civ. P., and certain accompanying exhibits contain material that the parties have designated as confidential, she seeks leave to file it under seal. Respectfully submitted, Meredith M, Esq. cc: Laura Menninger and Jeffrey Pagliuca via CWECF WWW.EISFLEP.COM EFTA02799383