giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1080.0
2 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…She was unable to crawl . .
.Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport
her to [REDACTED] to check on her condition. I then met with [REDACTED] and his
mother. I advised [REDACTED] of his Miranda rights . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…She was unable to crawl . .
.Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport
her to [REDACTED] to check on her condition. I then met with [REDACTED] and his
mother. I advised [REDACTED] of his Miranda rights . . …
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.885.0
7 pg
… however, once a party voluntarily discloses work product to an
adversary, the need for the privilege disappears.”); Grumman Aerospace Corp. v. Titanium
Metals Corp. of America, 91 F.R.D. 84, 90 (D.C.N.Y., 1981) (“Disclosure to an…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…Maxwell submits that consideration of the motions in chronological order is the
most logical, efficient and fair method to adopt. Plaintiff’s counsel proposes an ad hoc
approach in which filings appear to be selected in order to speed up…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…Churcher, who they fully
23 acknowledge reported stories about this case -- not this
24 litigation but the underlying case and who first met the
25 plaintiff when she traveled to Australia to interview her in
SOUTHERN DISTRICT REPORTERS, P.C…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
… Either way, there was to
15 be a showing by the party seeking to seal that a particular
16 test has been met with regard to the document at issue.
17 The courts have held pretty strictly, according to our…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…an individualized review of the sealed materials” was an abuse of discretion,
the Second Circuit in dicta “describe[d] certain methods courts can employ to” prevent records
from being used to “gratify private spite or promote public scandal” or “serve…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…identify the nonparties, to the extent that they are not already
public, shall be redacted.2
Counsel shall accordingly proceed with unsealing the relevant
materials by the method prescribed in the Court’s July 28 Order
(dkt. no. 1077) and…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…the party causing the
service shall file a certificate of service, stating the date and method of service and
identifying the Non-Party by his or her pseudonymous identifier.
c. Within 14 days of service of the Non-Party Notice…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…the party causing the service shall file a
certificate of service, stating the date and method of service and identifying the Non-
Party by his or her pseudonymous identifier.
c. Within 14 days of service of the Non-Party Notice…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…ruling, this court recognized the potential for persons to use court files “to
promote scandal arising out of unproven potentially libelous statements,” and
described various methods available “to protect the judicial process from being
coopted for such purposes.” Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…Sprint Corp., 407 F.3d 560, 562 (2d Cir. 2005) (“[P]ermissive intervention is the proper method
for a nonparty to seek a modification of a protective order.”); see also E.E.O.C. v. Nat’l Children’s
Ctr…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…After service, the party causing the service shall file a certificate of service,
stating the date and method of service and identifying the Non-Party by his or her
pseudonymous identifier.
c. Within 14 days of service of the Non…
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