Case 1:15-cv-07433-LAP Document 924 Filed 10/03/17 Michael C. 212 506 3955 [email protected] Page 1 of 2 Steptoe STEPTOE LLP 1114 Avenue of the Americas New York, NY 10036 212 506 3900 main www.steptoe.com VIA ECF October 3, 2017 Hon. Robert W. Sweet U.S. District Judge United States District Court for the Southern District of New York 500 Pearl Street New York, New York 10007 Re: v. Maxwell, 15-cv-7433-RWS - Regarding Protective Order Dear Judge Sweet: This is a letter motion, pursuant to this Court's Protective Order (Dkt 62) and the Southern District of New York Electronic Case Filing Rules & Instructions 6.2, for leave to file under seal Proposed Intervenors Jeffrey Epstein's and Lesley Groff's ("Intervenors") Memorandum of Law in Support of Intervenors' Motion for Leave to Intervene and Modify the Protective Order (the "Motion to Modify"). For the reasons set forth in the Motion to Modify, Matter in order to allow them to tive Order in the Intervenors seek to modify the Matter in support of a motion to dismiss another action use evidence produced in the against Intervenors, Jane Do 4 v Epstein, No. 17 Civ. 616, which is based on allegations e Matter. The evidence at issue was produced by Jane Doe 43, similar to those m ' a non-party in the Matter. Judge Koeltl, before whom the Jane Doe Matter is nding, Matter. instructed us to seek leave from this Court to modify the Protective Order in the ilk 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 (Dkt 62) signed on March 17, 2016, at p. 4. In order to demonstrate to the Court why the Protective Order should be modified, Intervenors have cited to and quoted from EFTA02804798