EFTA00017095

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The Newyork Time: Company David McCraw Vice President & Deputy General Counsel New York, NY 10018 nytimes.com September 10. 20 19 VIA FAX The Honorable Kenneth M. Karas United States District Judge The Hon. Charles L. Brieant Jr. Federal Buildin and United States Courthouse White Plains, NY 10601 Re: United States v. Tartaglione, 16-cr-832 — Unsealing of Judicial Records Dear Judge Karas: I write on behalf of The New York Times Company and reporter Benjamin Weiser (jointly, "The Times") regarding the Government's application to seal two recent filings in this case. The Times agrees with the New York Post and the Daily Netts (see Dkt. 155) that the application has no merit: the filings are judicial documents subject to the common law and First Amendment rights of access, and the high bar required for overcoming these rights has not been met.' The Government has sought to seal records related to Mr. Tartaglione's August 20, 2019 application to "be moved from the [Metropolitan Correctional Center] and detained at another facility." Dkt. 147 at 1. As the basis for his application, Mr. Tartaglione's counsel cited the "constant and deplorable" conditions at the MCC and perceived threats to his client's safety from MCC guards. Id. at 2. Those threats, he says, arise from his client's speaking up about both the conditions at MCC and the attempted suicide of his former and now-late cellmate Jeffrey Epstein. Id. at 1-2. The Government submitted a sealed