giuffre-maxwell
gov.uscourts.nysd.447706.1213.1
10 pg
…unsealing has not yet expired.
to Improper Objection
344 Already public.
346 Unseal in full. Note: Original parties agree.
346-1 Unseal in full. Note: Original parties agree.
Unseal and redact only names and identifying …
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties jointly write to seek clarification of the following parts of the Protocol
for Unsealing Decided Motions, ECF No. 1044:
at a time…
giuffre-maxwell
gov.uscourts.nysd.447706.1045.0
2 pg
…motions under its Order and Protocol (DE 1044). Unfortunately, counsel for the original
parties were unable to reach an agreement as to the sequence of motions. I also write to
submit a joint proposed redacted Decided Motions List.
First, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…is that the Non-Parties will
10 initially file their objection under seal. The Court then,
11 sometimes with information from the Original parties, will
12 prepare a redacted copy of those filings so that those can be
13 docketed…
giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…the
resolution of those factual issues.
7. Judicial Documents: In their submissions to the Court, non-
parties and the original parties may object to the unsealing
of a court submission because it is, in their view, a non-
judicial document…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed
Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed
Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively, the “Original Parties”) each have submitted under seal a list of non-parties whose
privacy, reputational or other interests may be implicated by the unsealing of the Sealed
Materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…if any, the Original Parties may
file an opposition stating the reasons why any Sealed Item should be unsealed.” DE 1108, at 3.
That same paragraph further provides the “objecting Non-Party may file a reply in support of its…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Airdata Wiman, Inc., 846 So.2d 664, 668 (Fla. 2nd
DCA 2003)) (emphasis in original). Indeed, in 2014, the Southern District of Florida rejected the
Hearn “at issue” analysis and instead, adopted the analysis of the Third Circuit as outlined…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…The Court notes that it has removed two documents from
24 the parties' chart which it believes were included on the chart
25 in error. First, the original chart lists Docket No. 258-10 as
SOUTHERN DISTRICT REPORTERS, P.C.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…Petitioners; rather, they seek to
join this proceeding as parties that could have been permissively joined in the original petition
under Rule 20 (“Permissive Joinder of Parties”). As courts generally use the standards of Rule
15 to evaluate such circumstances…
giuffre-maxwell
gov.uscourts.nysd.447706.977.1
25 pg
…final determination
of substantive legal rights, the public interest in access is not as pressing.” (internal
quotation marks omitted; emphasis in original)).
17 Lugosch, 435 F.3d at 121.
12
Case
Case
1:15-cv-07433-LAP
16-3945, Document
…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…Petitioners; rather, they seek to
join this proceeding as parties that could have been permissively joined in the original petition
under Rule 20 (“Permissive Joinder of Parties”). As courts generally use the standards of Rule
15 to evaluate such circumstances…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…2015, statement incorporated by reference “Ghislaine
Maxwell’s original response to the lies and defamatory claims remains the same,” an earlier
statement that had falsely described Giuffre’s factual assertions as “entirely false” and “entirely
untrue.”
32. Maxwell made the…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Airdata Wiman, Inc., 846 So.2d 664, 668 (Fla. 2nd
DCA 2003)) (emphasis in original). Indeed, in 2014, the Southern District of Florida rejected the
Hearn “at issue” analysis and instead, adopted the analysis of the Third Circuit as outlined…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…redacted name. Further, the Miami Herald correctly notes that the Protocol
permits the Court’s staff (with the assistance of the original parties) to redact the non-party
submissions and publicly file them via ECF. See DE 1225, at 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1028.0
5 pg
…filed.
Non-Party List. This list is intended to capture all non-parties who should be
notified if they are identifiably referenced in the sealed materials. The original
parties, non-party J.Doe and intervenors Ms. Brown and the Miami…
giuffre-maxwell
1320-18
40 pg
…Airdata Wiman, Inc., 846 So.2d 664, 668 (Fla. 2nd
DCA 2003)) (emphasis in original). Indeed, in 2014, the Southern District of Florida rejected the
Hearn “at issue” analysis and instead, adopted the analysis of the Third Circuit as outlined…
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