giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties write in response to the Court’s December 14, 2020, order directing
them to confer about a proposed next set of docket entries…
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.447706.1124.0_3
2 pg
…1055. Neither Doe
1 nor Doe 2 requested Excerpts under the Protocol, the Original Parties submitted their own briefs,
and the Court ruled that the first five motions, including portions of those documents mentioning
Doe 1 or Doe 2, should…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1192.0_3
3 pg
…publicly disclose or file on the public docket the names or
identifying information of non-party Does (except for Mr. Dershowitz) in materials originally
1
Unless otherwise noted, Docket Entries refer to the Dershowitz case.
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1038.0
2 pg
…the situation
in which a Non-Party does not object to a document’s unsealing, be changed to provide the
Original Party objecting to unsealing (i.e., Defendant) with an automatic right to file a reply brief.
But because this…
giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…1
In deciding Ms. Maxwell’s Motion to Stay Discovery (Doc # 18), this Court agreed with
Plaintiff’s original contention, stating “this case involves a single claim against a single
defendant, relating to an ongoing series of events in which…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…time to object to the unsealing of the Doe 1 and 2
materials at issue in this second round.
The Original Parties and the Court received a request for excerpts for sealed materials
from Does 1 and 2 on Friday…
giuffre-maxwell
gov.uscourts.nysd.447706.1107.0
2 pg
…as well as
documents relevant to those motions.
2. Notification of Non-Parties: The Original Parties shall send
the Non-Party Notice to all remaining Non-Parties.
3. Response Times: Paragraphs 2(d) and 2(e) of the Protocol will
…
giuffre-maxwell
gov.uscourts.nysd.447706.1229.0
3 pg
…1228).
Doe’s letters propose that non-party objections to unsealing that were not opposed by
either of the original parties – because the parties relied on an order by this Court telling them
not to respond – should be “summarily sustained…
giuffre-maxwell
gov.uscourts.nysd.447706.1143.0_1
2 pg
…1108 ¶ 2f (providing that
“the Original Parties shall have 7 days from the date on which the Non-Party’s time to object
expires to submit an objection to unsealing and an accompanying memorandum. Any opposition
to such an objection…
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.447706.1125.0_2
5 pg
…a formal objection to unsealing. The original parties to
this action may file their own objection to unsealing no later
than (1) 7 days after service of any formal objection by Does 1
and 2, as provided by Paragraph 2…
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…