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Case 1:20-cr-00330-PAE Document581 Filed 01/24/22 Page5of5 January 21, 2022 Page 5 Proposed Intervenors therefore respectfully request that the Court unseal Ms. Maxwell’s motion for a new trial, and its related exhibits, in their entirety, as well as future submissions related to this motion. Proposed Intervenors do not expect that Ms. Maxwell can prove that “closure is essential to preserve higher values” that outweigh the public’s right of access to any portion of the filings. See Donato, 714 F. App’x at 76. However, if she can prove such higher values exist, Proposed Intervenors request that such information be subject to limited redactions and that the remainder of the filings be unsealed. See id. (noting that, even where sealing is appropriate, it must be “narrowly tailored” by applying redactions rather than withholding the document in its entirety). Sincerely yours, HOLLAND & KNIGHT LLP /s/ Christine N. Walz Christine N. Walz Sanford L. Bohrer Cynthia A. Gierhart Counsel for The Miami Herald and Julie Brown DOJ-OGR-00008828