…submission may also include labeling certain docket entries as including information that was put forth in Defendant’s view for an “improper purpose.” Defendant did not challenge these submissions in the underlying action despite having the opportunity to do so…
…related to such nonparties’ specific conduct will be redacted from the materials being unsealed. Disclosure of the additional nonparty names will await notice to those parties and an opportunity for them to be heard.” Id. 5:20-6:1. Plaintiff…
…requested Excerpts (and who therefore do not intend to object to unsealing) will also be exceedingly helpful to the Original Parties tasked with redacting the names of Non-Parties who have not yet had the opportunity to object to unsealing…
…Maxwell believes that her proposed additional redactions comport with the Court’s direction that Non-Parties be given the opportunity to review and object before any information identifying their identity or any conduct attributed to them (including as either an…
…countervailing interests rebut the presumption of public access. To assist in this process and afford persons identified or otherwise interested in the Sealed Materials the opportunity to participate in the Court’s individualized review, the Court adopts the following protocol.…
…Finally, the materials at issue should not be released publicly because the criminal court overseeing Ms. Maxwell’s criminal prosecution has not yet had an opportunity to determine whether the evidence will be admissible at trial or suppressed. I. As…
…and 3, implicit in the Court’s Order and Protocol for Unsealing Decided Motions, was to afford each Nonparty the opportunity for notice and the chance to be heard prior to unsealing materials that implicate their privacy rights. (Doc. 1044…
…countervailing interests rebut the presumption of public access. To assist in this process and afford persons identified or otherwise interested in the Sealed Materials the opportunity to participate in the Court’s individualized review, the Court adopts the following protocol.…
…countervailing interests rebut the presumption of public access. To assist in this process and afford persons identified or otherwise interested in the Sealed Materials the opportunity to participate in the Court’s individualized review, the Court adopts the following protocol.…
…after substantial input from the parties, is achieving its desired purpose of: (a) attempting to provide notice and an opportunity to object to non-parties to the release of Sealed Materials; (b) establishing a fixed schedule and procedure for both…
…ARGUMENT I. PLAINTIFF’S VIOLATION OF THIS COURT’S ORDER TO PRODUCE DOCUMENTS IS NOT AN OPPORTUNITY FOR HER TO RE-LITIGATE THE ISSUE. Plaintiff has been attempting to dodge the production of these documents for months. First, Plaintiff claimed…
…2 of 4 the First Five Motions (and their accompanying papers) that those documents may be unsealed, and that once all Non-Parties whose name appears in the First Five Motions are notified and have had an opportunity to object…
…to (1) ensure that redacted versions of the Does’ objections are filed on the public docket and (2) ensure that Intervenors have an opportunity to respond to the Does’ objections. The court outlined the following procedure regarding placement of the…
…countervailing interests rebut the presumption of public access. To assist in this process and afford persons identified or otherwise interested in the Sealed Materials the opportunity to participate in the Court’s individualized review, the Court adopts the following protocol.…
…Maxwell seeks here to preserve her right to a fair opportunity to challenge the government’s unconstitutional and unlawful conduct in obtaining access to deposition Case 1:15-cv-07433-LAP Document 1204 Filed 01/29/21 Page 2…
…provided. J. Doe 1 will then have the opportunity to file a single Objection to the unsealing of all such excerpts once rather than separate objections submitted three or four times. Many of the Excerpts are redundant across pleadings, it…
…under seal in 1 Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 6 of 24 their entirety until every Non-Party listed therein receives notice and has an opportunity to request excerpts and object…
…belatedly, ask that their names not be disclosed, 24 after the horse was already out of the barn. They were given 25 an additional opportunity to lodge formal objections, but did SOUTHERN DISTRICT REPORTERS, P.C.•• (212) 805-0300 …
…of course, as 20 we discussed, as is discussed in the proposed revised protocol, 21 then after the non-parties respond -- if they do -- then you 22 would have an opportunity to put in your countervailing 23 interests. So, maybe…
…are verified. Similarly, a court may consider whether the nature of the materials is such that there is a fair opportunity for the subject to respond to any accusations contained therein.” Amodeo, 71 F.3d at 1051 (emphasis added); see…
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