…competing proposals for streamlining the unsealing process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224. We write to express our views regarding the parties’ respective submissions, as well as that offered by the Miami Herald…
…process. At the July 26 meet and confer, Maxwell’s counsel expressed that they would be unable to carry out the Court’s suggestion due to scheduling conflicts until January of next year, and asserted 1 The Non-Party Objectors…
…Order. For example, Doe # 84 is an individual who testified at a deposition, represented by counsel, under the express promise of confidentiality under the Protective Order. This individual accused Mr. Epstein of wrongdoing perpetrated when the individual was minor. During…
…it seeks “may be obtained more expeditiously herein than through duplicative discovery in its separately filed action.” DE 1111 at 12. But this Court has already expressly rejected this precise argument. See DE 1071 at 7-8. Nor is Mr…
…used appropriately broad, but tailored search terms, including, but not limited to the names of the individuals expressly listed in Plaintiff’s Requests for Production as well as the e-mail addresses of those individuals, if known. Ms. Maxwell is…
…at 2. Although not expressly stated, presumably Plaintiff’s position is based on the Court’s prior rejection of Plaintiff’s position that if a non-party fails to object, the materials pertaining to that non-party should be automatically…