WILIVILY CINDVVYAOLLY Cc Ov I N G T Oo N Arlo Devlin-Brown Covington & Burling LLP BEIJING BRUSSELS DUBAI FRANKFURT JOHANNESBURG The New York Times Building LONDON LOS ANGELES NEW YORK PALO ALTO 620 Eighth Avenue SAN FRANCISCO SEOUL SHANGHAI WASHINGTON New York, NY 10018-1405 T +1212 8411046 [email protected] By ECF May 26, 2020 The Honorable Edgardo Ramos United States District Judge United States Courthouse 40 Foley Square New York, New York 10007 Re: Fernandez-Rodriguez et al. v. Licon-Vitale, No. 20 Civ. 3315 (ER) Dear Judge Ramos: This firm is counsel to Petitioners in this action. I write pursuant to paragraph I.A of Your Honor’s Individual Practices and Section 6 of the Court’s ECF Rules and Instructions conceming Petitioners’ Motion for a Preliminary Injunction, which is due to be filed later today. As an initial matter, given the complexity of the issues presented, Petitioners respectfully request leave to file a memorandum of law of up to 30 pages. The Government consents to this request. In addition, Petitioners’ papers will include certain discovery documents relating to prison operations that the Government has designated as Protected Information under the Protective Order in this case (ECF No. 29). We respectfully request that the Court permit us to file the materials in question, which will include photographs and potentially internal memos and policy documents, under seal. See, e.g., Richards v. Cox,

, *1 (D. Nev. June 18, 2019) (permitting sealing of certain internal documents concerning prison operations); Clark v. U.S.,

, *1 (N.D. Ga. May 17, 2012) (permitting sealing of certain BOP policy documents). Pursuant to Rules 6.4 and 18.1 of the Court’s ECF Rules and Instructions, our understanding is that, upon entry of a sealing order, we ordinarily would be required to deliver an envelope containing paper copies of this letter and the proposed-to-be-sealed documents to the court’s depository box located in the lobby of the 500 Pearl Street courthouse. We would be grateful if Your Honor would consider obviating such a submission by ordering that Petitioners may file the materials under seal electronically through the ECF system or by email delivery to chambers. The application is GRANTED. The petitioners may file a memorandum of law of up to 30 pages. The petitioners may also file discovery documents designated as Protected Information under Respectfully submitted seal. The petitioners are directed to do so via ECF and need not do P y ° so via physical delivery. pny □ s/ Arlo Devlin-Brown

Edgardo Ramos, U.S.D.J