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Case 1:15-cv-07433-LAP Document 1078 Filed 08/10/20 Page 3 of 3 Honorable Loretta A. Preska August 10, 2020 Page 3 providing the Notice to Doe 1 at the new address for any future pleadings that implicate his or her deposition, which is currently subject to the Second Circuit's stay. Third, to prevent against some of the errors that occurred during the last round of unsealing, we request that the Protocol be amended to require the Redacted Original Party who proposes unsealing to supply with their Response a corresponding unredacted set of the pleadings at issue, for the Court's consideration of the Original Party or Non-Party materials. This list allows much leeway into the Court's ruling and we believe the Court's ruling should specify which redactions are accepted or rejecting at the time of ruling. Finally, we request that the Court allow for the any objecting Non-Party or Original Party be given 7 days following any unseal order to apply for relief in the Second Circuit from the order prior to the documents being released. Proposed Next Set of Docket Entries for Review: Given the Second Circuit's stay concerning Ms. Maxwell and Doe 1's deposition transcripts and materials that quote from them, we propose that the Court deviate from the given chronology (given that Doe 1's deposition is sprinkled throughout those motions) and instead take the following five decided motions that (a) have been sub or redacted from documents submitted or redacted and (b) do not stay. They are: 75 - Defendant's Motion to Compel Responses to Defendant's First Set of Discovery Requests 139 - Plaintiff's Brief in Support of the Privilege Claimed for In Camera Submission 155 - Defendant's Motion to Compel Non-Privileged Documents 215 - Sharon Churcher Motion to Quash Subpoena 231 - Defendant's Motion to Reopen Deposition of Plaintiff Virginia Giuffre Counsel for Ms. Maxwell is available for a telephone conference to discuss any of the foregoing, should the Court desire. Respectfully submitted, Laura A. Menninger CC: Counsel of Record via ECF DOJ-OGR-00019323