Case 1:15-cv-07433-LAP BSF Document 793 Filed 03/27/17 Page 1 of 2 BOIES SCHILLER FLEXNER Meredith = Esq. E-mail: [email protected] March 27, 2017 VIA 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 Dear Judge Sweet, On March 15, 2017, Plaintiff's submitted proposed redactions to Defendant of this Court's February 16, 2017 hearing transcript. In response Defendant's counsel has made a blanket unsupported challenge to all proposed redactions. At the summary judgment hearing, this Court heard argument on Defendant's motion for summary judgment. Defendant's counsel submitted his entire summary judgment motion and reply brief under seal, as did counsel with her response. The summary judgment argument discussed the same issues that Defendant and Plaintiff previously filed under seal. Accordingly, that portion of the transcript should be kept under seal. Despite Defendant's counsel filing his entire motion for summary judgment and reply under seal, Defendant takes a different view about the oral argument based upon those briefs. On March 21, 2017, counsel for Defendant, Ty Gee, sent a letter (attached) to counsel for stating: We object under Paragraph 11 of the Protective Order (Doc.62) to plaintiff's "confidential" designation (see Docs.721 & 721-1) of the transcript of the February 16 hearing. No portions of the transcript plaintiff has [sic] designated are confidential under the Protective Order. This is the second time Defendant has challenged a confidentiality designation made by =. As the Court will recall, Defendant's first (and failed) attempt sought to make public certain materials that are not only protected from public view by various statutes, but also by a common sense of decency. While Defendant's counsel gives no reason in his letter why he wants the hearing transcript revealed, it is somewhat perplexing given that he wants to keep