giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order, dated Dec. 16,
2019 (DE 1016)…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order, dated Dec. 16,
2019 (DE 1016)…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order, dated Dec. 16,
2019 (DE 1016)…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order, dated Dec. 16,
2019 (DE 1016)…
giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…previously
disclosed and could cause severe irreparable harm if revealed. The soonest date that
Doe 171 and her undersigned counsel expect to be capable of seeking an emergency
temporary stay pending appeal in the Second Circuit is December 2, 2022…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…documents by Non-
Party rather than by motion. In that letter, the parties shall
also propose a date for a telephonic conference to discuss next
steps in the unsealing process.
SO ORDERED.
Dated: New York, New York
March 19, 2020
_____…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…the United State& Attorney for the Southern District ofFloridadofer such
prosecution. Epstein agrees and consents that any delay from tho date of thil Agreement to
the daM of initiation of pro,ecution, as provided for in the terms expressed heniD…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.1_2
28 pg
…315, 320, & 335
DOCKET DATE COUNTERVAILING
# FILED DEFENDANT’S POSITION
INTERESTS1
Redact all quotes from Ms.
Maxwell and Non-Par…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…participate via
telephone. Accordingly, we respectfully request that the conference be
rescheduled for a later date.1
Respective counsel for intervenors Miami Herald, Julie Brown and Alan
Dershowitz do not oppose our request to continue the conference. Sanford
Bohrer for…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…the
Court explicitly ruled, “[A]ll documents, materials, and information subject to the Protective
Order must be returned to the party who designated its confidentiality as of the date this action
was dismissed.” Sealed Op., at 3 (Nov. 14, 2017) …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Compel. Cassell and
Edwards also explained that communications with Ms. Giuffre were protected not only
beginning in March 2014, but even earlier than that date when Ms. Giuffre understood that she
was obtaining legal services from Cassell and Edwards. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…list
22 with the Doe I and II down the side. Maybe I missed that.
23 THE COURT: Let me just see. Will you recall the date
24 on the letter that that came in with?
25 MR. LEWIN: Judge…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…315, 320, & 335
DOCKET DATE COUNTERVAILING
# FILED DEFENDANT’S POSITION
INTERESTS1
Redact all quotes from Ms.
Maxwell and Non-Par…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Compel. Cassell and
Edwards also explained that communications with Ms. Giuffre were protected not only
beginning in March 2014, but even earlier than that date when Ms. Giuffre understood that she
was obtaining legal services from Cassell and Edwards. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…implicated.
As for the parties’ submissions concerning streamlining the Protocol, neither proposal is
workable as stated without undermining the Protocol. To date, several phases of the Protocol
have been completed. Through the original parties’ efforts and the Court’s rulings…
giuffre-maxwell
1320-18
40 pg
…Compel. Cassell and
Edwards also explained that communications with Ms. Giuffre were protected not only
beginning in March 2014, but even earlier than that date when Ms. Giuffre understood that she
was obtaining legal services from Cassell and Edwards. Id…
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