…Order and Protocol Governing the Excerpts (“Non- Party Request”); • Form – Non-Party’s Objection to Unsealing (“Non-Party Objection”). The original parties have conferred between themselves and with counsel for Intervenors Brown and Miami Herald and for J. Doe (collectively…
…the Dershowitz case. 2 We also request that any de-designation of Confidential Information of presently sealed materials in Maxwell – or any other agreement between the Dershowitz parties – or any filing of presently sealed materials that identify any non-party…
…173-4, 173-10, which Maxwell argues are not judicial documents because they contain “various back and forth emails between counsel.” Maxwell Mem. at 11-12. These docket entries are already available to the public in full on the docket…
…13 272-9. Correspondence which may be unsealed by the 14 agreement of the parties. Correspondence between Bernadette 15 Martin and Meredith Schultz. 16 272-10. Excerpts from Ms. Giuffre's deposition. 17 Already publicly filed at docket entry 1090…
…MENNINGER: Your Honor, I believe there are some 4 discrepancies between counsel's lists. 5 THE COURT: We will figure it out. 6 MS. MENNINGER: If we can get the most complete one 7 and do that. 8 THE COURT…
…need to coordinate with 3 counsel. Of course the three arm, purple hair example is one, 4 but there is ample public information about relationships 5 between people and the like that, if not redacted, could cause 6 a nonparty…
…s reliance on Amodeo and the Second Circuit’s note about unverified information is misplaced. The Amodeo court drew a two-part distinction between unsealing different parts of the report at issue in that case. 71 F.3d at 1052…
…this case within a case.5 Id. In addition to the perjury counts (Brief at 10-11), there exists substantial overlap between the witnesses and testimony in this case and those likely to testify in the criminal action. First, Ms…
…given to the plaintiff and she is then 20 changing her story to make it more salacious and more sellable 21 to various people through the world. 22 There is a series of exchanges between the plaintiff 23 and Ms…
…information about Ms. Giuffre, Defendant apparently does not want the world not know that she continues to maintain 12 Defendant has even filed an Affidavit from Dershowitz’s attorney which states that there is a common interest between them. Curiously…
…access or a social media account. It is not possible to overstate the close relationship between the documents plaintiff wants to unseal in this case and the criminal prosecution the government is pursuing next door. Indeed one of the very…
…Virginia. 5 Our position is if one docket entry is opened, all 6 must be opened. There can be nothing in between because what 7 would happen is if, for example, as what was presented to the 8 Court previously…
…document. DE 173-1 exhibits 1-4 identify additional Non-Parties. Generally, these exhibits are a composite of various back and forth emails between counsel which are hearsay, non-judicial, documents and which contain the identity of Non-Party Does…
…as his Counsel. It also does not limit substitution to the Second Circuit case. In any case, Ms. Maxwell’s arguments about any conflict of interest between Counsel’s interests and Ms. Giuffre’s interests are unfounded. Ms. Giuffre has…
…case had identified a decided summary judgment motion as a judicial document, we identified no material distinction between decided 17 Case: Case:24-182, 24-182,01/08/2026, 07/23/2025,DktEntry: …
…10 September 3, 2019 Page 4 of 7 1995) (“Documents that play no role in the performance of Article III functions, such as those passed between the parties in discovery, lie entirely beyond the presumption’s reach.”). Nevertheless, should the…
…by the protective order. See id. None of those bases are present here. Movant recognizes that “documents such as those passed between the parties in discovery often play no role in the performance of U.S. Const. Art. III functions …
…4:A lld ocu ments relatingto commu nications between you and J effrey E pstein regard ingany female u nd erthe age of 18 from the period of 1999 –present. RESPONSE: M s.M ax wellhas been u nable to…
…to testify for any number of reasons, and there is no correlation between granting a motion to compel (which simply requires a showing of relevancy and lack of privilege), with sealing (which requires a showing of good cause). See Fed…
Comments