gov.uscourts.nysd.447706.1082.0.pdf

Case 1:15-cv-07433-LAP Document 1082 Filed 07/30/20 Page 1 of 1 Haddon, Morgan and Foreman, P.C Laura A. Menninger 150 East 10th Avenue Denver, Colorado 80203 PH 303.831.7364 FX 303.832.2628 www.hmflaw.com [email protected] July 30, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Motion to File Under Seal Giuffre v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Dear Judge Preska: This is a letter motion seeking leave to permit Ms. Maxwell to file a redacted Letter to the Court and her proposed redactions to Sealed Materials under seal. The Protective Order governing this case 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. Doc. # 62 at 4. The Letter to the Court and the proposed unredactions contain information deemed CONFIDENTIAL by the parties pursuant to the Protective Order. References to and discussion of specific CONFIDENTIAL materials are necessary to support Ms. Maxwell’s request that certain materials remain under seal pending notification to other Nonparties. Ms. Maxwell intends to file the redacted version of the Letter publicly on ECF and seeks leave only to file the unredacted version and the proposed unredactions under seal. Respectfully submitted, Laura A. Menninger CC: Counsel of Record via ECF