Case 1:15-cv-07433-LAP Document 811 Filed 03/29/17 RANDAZZA Page 1 of 2 Jay Marshall Wolman. JD NY. DC Licensed in CT. LEGAL GROUP 29 March 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 I Case No.: 15-cv-07433-RWS Dear Judge Sweet: Movant-Intervenor Michael Cernovich d/b/o Cernovich Media was previously unable to divine from the publicly available portions of Plaintiff's Notice of Intent to Request Redaction (Doc No. 721) what redactions were sought, thus limiting his ability to file his opposition thereto (Doc. No. 725). Plaintiff's March 27, 2017 letter (Doc. No. 793) has finally revealed what portion of the February 16. 2017, transcript she is seeking to redact: the entire portion that is the summary judgment argument. Movant hereby responds to Plaintiff's letter. It appears now that Defendant, at least, recognizes the fundamental problem under the common law right of access and the First Amendment in sealing any portion of the summary judgment argument. And, Plaintiff has now revealed in her letter that the oral argument "hewed so closely to the content of the sealed brief that much of the hearing transcript consists of him simply reading portions of those briefs aloud". If this is the case, then it is even more apparent there is no basis for sealing the summary judgment pleadings, let alone the transcript. Undersigned counsel was present at the proceedings. Defendant's counsel invited the Court to seal the courtroom in advance of his argument, but the Court indicated such would be unnecessary. The Court wos correct and, though at any time Plaintiff could have asked for a seal mid-argument, none was sought. Now, Plaintiff is trying to close the proverbial barn door after the horses hove escaped. Not only is redaction frivolous, as it would only limit public access to verbatim arguments, rather than the substance of the arguments themselves, but there are n