… receipt of the Notice to nearly half of the 91 Non-Parties to whom Ms. Maxwell attempted service was never confirmed; plaintiff’s counsel has not said how many of the 90+ Non-Parties parties it served actually received the…
…are unfounded. Ms. Giuffre has repeatedly confirmed that her interest was that all of the filings in the district court docket should be unsealed so that the public may have a complete picture of the abuse she suffered. (Dkt. 945…
…982. The parties met and conferred several times over the past two weeks, and were able to reach agreement with the exceptions of Categories 4 and 10 below. Plaintiff believes that all documents concerning trial deposition designations (including objections and…
…ECF No. 1108. The Parties met and conferred on July 26, and discussed ways in which the sealing process can proceed more efficiently. The Parties therefore present the following options to the Court. Plaintiff’s Proposal At the July 1…
…in her opinion, they were under-inclusive. The parties met and conferred on July 29, and disagreed as to what constitutes “nonparties’ specific conduct” requiring redaction. Plaintiff’s understanding of the Court’s order is that the documents are to…
…1131), Plaintiff sent Maxwell copies of her proposed redactions yesterday evening 2 and scheduled a telephone conference to discuss those materials today. The parties met and conferred this afternoon, but could not reach agreement on the materials to be unsealed…
…Plaintiff’s proposed redactions. Counsel reviewed the proposed redactions to Ms. Maxwell’s 465-page deposition transcript and conferred with Plaintiff’s counsel regarding her proposed redactions during a telephone conference at 1 p.m. today. While undersigned counsel explained…
…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…
…whose “intimate, sexual, or private conduct is described in the Sealed Materials,” and (d) persons who allegedly have been victimized. Id. at 1. The parties conferred on July 29, 2020. Plaintiff, after making some changes to address these concerns, plaintiff…
…for Excerpts, and the Non-Party Form Objection. Counsel conferred with plaintiff’s counsel concerning these proposed revisions, who object for reasons that they intend to explain to the Court by separate letter. Ms. Maxwell believes the proposed changes, as…
…and 5, and we respectfully submit that we simply cannot complete the task within the time allotted. We conferred with Plaintiffs’ counsel, who said she would not agree to more than seven additional days. We submit there is good cause…
…she would be unlikely to meet a November 8 deadline given the schedule for her criminal trial. The parties met and conferred on October 20, and Defendant agreed to Plaintiff’s proposed list of non- party objectors on October 29…
…the Court’s Order of March 23,2020 (DE 1036), the parties conferred and hereby submit a joint proposed redacted Decided Motions List to be filed on the public docket. Because the parties identified two minor numbering changes (with respect…