…v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S RESPONSE IN OPPOSITION TO MOTION FOR PROTECTIVE ORDER AND MOTION FOR THE COURT TO DIRECT DEFENDANT TO DISC…
…279, 315, 320 & 335 and to file under seal Exhibit D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall…
…cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) Sig…
…redacted Letter to the Court and her proposed redactions to Sealed Materials under seal. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter…
…cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ REPLY IN SUPPORT OF PLAINTIFF’S MOTION FOR PROTECTIVE ORDER AND TO DIRECT THE DEFENDANT TO DISCLOSE ALL INDIVIDUALS TO WHOM DEFENDANT HAS DISSIMINATED CONFIDENTIAL INFORMATION (DE 335) Sig…
…Objections to Unsealing Sealed Materials and to file under seal Exhibits A-D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter…
…to file her second July 30, 2020 letter on the public docket with redactions. The letter contains certain information deemed confidential pursuant to the Protective Order and that Maxwell redacted in her July 30, 2020 letter. DE 1083. Plaintiff intends…
…831.7364 FX 303.832.2628
www.hmflaw.com
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Because the Court finds that sealing would protect
July 1, 2020
…v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S RESPONSE IN OPPOSITION TO MOTION FOR PROTECTIVE ORDER AND MOTION FOR THE COURT TO DIRECT DEFENDANT TO DISC…
…through counsel. These Non-Parties were guaranteed, by Plaintiff’s counsel, that their testimony would remain confidential subject to the Protective Order. Nothing further should be required. Apart from the Protocol, there are practical problems with Plaintiff’s position. First…
…(ii) clarify whether it will accept and maintain as confidential additional ex parte submissions in further support of her request to seal, (iii) establish a schedule to address the issues related to the sealing of documents pertaining to Doe 171…
…essential facts leading to Ms. Maxwell’s July 2016 deposition: • Plaintiff moved to compel the deposition, promising that “any answers will be maintained as confidential under the Protective Order in this case” (Brief at 2); • Ms. Maxwell objected to the…
…315, 320 & 335 and to file under seal Exhibit E thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be…
…279, 315, 320 & 335 and to file under seal Exhibit D thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall…
…been rejected by this Court numerous times. The Second Circuit has held that “the mere existence of a confidentiality order says nothing about whether complete reliance on the order to avoid disclosure 1 Again, Intervenors do not have access to…
…pages ) but not in others (e.g., page ). Both of these two alleged victims are represented by counsel and sought confidentiality for their depositions; neither has yet been afforded notice or an opportunity to be heard with respect to this…
…See DE at 1224, at 5. Plaintiff and Defendant each generously designated materials as confidential under the Protective Order, and the process of determining what excerpts to unseal from such a voluminous record is necessarily challenging, particularly given the significant…
…compelling reasons. Movant cannot guess what Plaintiff seeks to redact, but none of the bits of information revealed during the hearing raised any significant confidentiality concerns that warranted sealing the courtroom or the order. See Newsday LLC v. Cty. of…
…materials from this case. 2 The Dershowitz Protective Order addresses the handling and treatment of documents designated by Ms. Giuffre and Mr. Dershowitz as “Confidential Information.” See DE 227 ¶ 2. It defines Confidential Information to include, inter alia, “information filed…
…315, 320 & 335 and to file under seal Exhibit E thereto. The Protective Order governing this case states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be…
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