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.447706.1213.1
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.447706.1025.0
17 pg
…Order and Protocol Governing the Excerpts (“Non-
Party Request”);
• Form – Non-Party’s Objection to Unsealing (“Non-Party Objection”).
The original parties have conferred between themselves and with counsel for
Intervenors Brown and Miami Herald and for J. Doe (collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.981.0
2 pg
…No.: 1:15-cv-07433-LAP
Dear Judge Preska:
Intervenor Michael Cernovich d/b/a Cernovich Media originally sought to intervene and
unseal the wholly-redacted summary judgment documents filed by Defendant Ghislaine
Maxwell and the subsequent summary judgment documents…
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.447706.1034.0
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.447706.1167.2
27 pg
…unsealing has not yet
232-8 6.20.16 on Protective Order; potential
C1-2 expired.
C1-3 Note: The Original Parties sent
witness in criminal trial …
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.447706.1289.0
3 pg
…motion for
reconsideration “shall be served withing fourteen (14) days after the entry of the Court’s
determination of the original motion” and “shall” include “a memorandum setting forth concisely
the matters or controlling decisions which counsel believes the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1266.0
4 pg
…s discretion under Rule 24(b)(2)
is very broad.”). In exercising its discretion, the Court is
required by rule to “consider whether the intervention will
unduly delay or prejudice the adjudication of the original
parties’ rights.” Fed. R. Civ…
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.447706.1090.7
11 pg
…7 impact or their right or anybody else's right to
8 go back to Judge Lynch and ask for more time from
9 this witness based upon my ruling or my reading of
10 the original order.
11 MS…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…only names and identifying information of
Non-Parties who have objected to unsealing or whose time to
object to unsealing has not yet expired.
232-8
Note: The Original Parties sent the Non-Party deponent (Doe 131)
…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…s Reply/Combined
Opposition; therefore, the redaction of non-party’s name on page 1 and signature block
on page 23 do not affect the original un-redacted reply or supporting declaration
submitted to the Court. Accordingly, re-filed DE…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…reflected in the attached redlined
version, are appropriate for the following reasons:
2(d): One or both of the Original Parties may want to oppose a Non-Party Objection
by arguing for un-sealing. Any argument by an Original Party…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 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.447706.1167.0
31 pg
…320, & 335. Ms. Maxwell amended her
original chart to, inter alia, include Plaintiff’s position, to correct some entries wherein the
Case 1:15-cv-07433-LAP Document 1167 Filed 12/01/20 Page 2 of 3
Second Circuit…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…
[6]
plaintiffs pled plausible claim that defendant was [4]
directly liable for alleged defamation; and Libel and Slander
By others in general
© 2016 Thomson Reuters. No claim to original U.S. Government Works. …
giuffre-maxwell
gov.uscourts.nysd.447706.1332.10
64 pg
…12 we actually had on the agenda, Jeff and I spoke about wanting
13 to talk to you about this today. We had originally anticipated
14 a two-week trial. We have set aside our experts, other
15 individuals that…
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