giuffre-maxwell
gov.uscourts.nysd.447706.1278.0
4 pg
…Maxwell, Case No. 1:15-cv-07433-LAP
Dear Judge Preska:
On behalf of non-party Doe 171, we file this letter motion for extension of the
stay pending appeal that Your Honor ordered on November 19, 2022, (Dkt.
No…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.5
3 pg
…1 is a true and correct copy of September 2,
2008, Victim Notification Letter (GIUFFRE001203-GIUFFRE001205).
4.
-
Attached hereto as Sealed Exhibit 2 is a true and correct copy of Excerpts of
January 16 2016, Deposition of Virg…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…parties’ counsel conduct
a review of the sealed and redacted materials, confer and inform the Court by letter
about the identity of non-parties identified in the material, and confer and inform the
Court by letter of any material in…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…2020
The Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Defendant Maxwell’s Letter Brief re Materials That Should Remain Sealed or
Redacted
Giuffre v. Maxwell, No…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…No. 348), this Court stated:
To reduce unnecessary filings and delay, it is hereby ordered that letter motions to
file submissions under seal pursuant to the Court’s Protective Order, ECF No. 62,
are granted. The Protective Order is amended…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…Preska:
On behalf of non-party, John Doe, we write in response to Plaintiff’s letter of August 5,
2021, see DE 1227.
Our letter of August 4, 2021 suggested several proposals to help expedite the continued
implementation of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…John Doe, in response to the letters filed by the
parties in the above-referenced case offering competing proposals for streamlining the unsealing
process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224.
We write to…
giuffre-maxwell
gov.uscourts.nysd.447706.1032.0
1 pg
…and believes our
respective lists contain identical information disclosed in slightly different ways, with one
exception. As outlined in her letter to this Court on November 12, 2019 (DE # 1007), Ms.
Maxwell submits that DE # 468 and 567 were motions…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…please, when you
2 speak to say your name first so that the court reporter is able
3 to do a good transcript.
4 We have looked at your various letters regarding the
5 protocol, and with respect to paragraph…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…non-parties.
6. Evidentiary Hearings: The Court will allow the parties or
non-parties to request by letter that the Court hold an
evidentiary hearing to resolve any factual issues underlying
the unsealing of specific documents. Any such request shall…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.8
4 pg
…hereto as Sealed Composite Exhibit 5 is a true and correct copy of E-mail
Correspondences to Laura Menninger.
8. Attached hereto as Sealed Composite Exhibit 6 is a true and correct copy of
Medical Release Letter to Providers.
9. …
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…the conference. We
had not received any communication from counsel for intervenor Cernovich as
of the time we said we would need to submit this letter to the Court.
Very truly yours,
Ty Gee
C: Counsel of Record (via ECF);…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.6_2
4 pg
…E-mail
Correspondences to Laura Menninger.
8. Attached hereto as Sealed Composite Exhibit 6 is a true and correct copy of
Medical Release Letter to Providers.
9. Attached hereto as Sealed Composite Exhibit 7 is a true and correct copy…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…172, 199 and 230. Accompanying this
letter (and filed under seal) are two charts listing all the filings from the Decided Motions List
which contain references to J. Does 1 & 2, plus an additional column which pinpoints the
reference in…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…affirmatively request an evidentiary hearing. Any
such request shall be made by letter explaining any factual issues that exist with a Sealed
Item (or Sealed Items) and the reasons that an evidentiary hearing may facilitate their
resolution.
j. After objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…by Ms. Maxwell in her letter stating that she
8 takes no position.
9 The Court has also considered the submission from
10 intervenors Julie Brown and Miami Herald Media Company.
11 Perhaps most importantly for our purposes today, the…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…Order that effectively ceded
control of the sealing process to the parties themselves. The Sealing
Order disposed of the requirement that the parties file individual letter
briefs to request sealing and prospectively granted all of the parties’
4 Fed. R…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…and September 6, 2018, we
proposed by letter a procedure for “joint compliance” with Paragraph 12 of the Protective Order
that would result in destruction of the protected materials in the parties’ possession, custody and
control. See Doc.958-1…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…affirmatively request an evidentiary hearing. Any
such request shall be made by letter explaining any factual issues that exist with a Sealed
Item (or Sealed Items) and the reasons that an evidentiary hearing may facilitate their
resolution.
j. After objections…
giuffre-maxwell
gov.uscourts.nysd.447706.968.0_1
26 pg
…Order that effectively ceded
control of the sealing process to the parties themselves. The Sealing
Order disposed of the requirement that the parties file individual letter
briefs to request sealing and prospectively granted all of the parties’
4 Fed. R…
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