…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 …
…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…
…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…
…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…
…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…
…Id. at 55–56, 67 (emphasis in original). There, the Second Circuit reversed a trial court’s order permitting the release of a videotaped deposition of a non-party adult discussing the sexual abuse he suffered as a minor, even…
…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 …
…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…
…July 29,” (dkt. no. 1083 at 1), Ms. Giuffre at a minimum gave the Court time to conduct a review of her proposed redactions while preserving the original schedule for unsealing. By contrast, Ms. Maxwell at 2:00 p.m…
…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) …
…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…
…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…
… 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…
…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…
…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…
…August 27, 2020: The Court’s staff will receive Non-Party submissions, make appropriate redactions, e.g., the Non-Party’s identifying information (with the assistance of the Original Parties, as appropriate), substitute Non-Party pseudonymous identifiers as appropriate, redact…
…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…
…Docket Entries 143, 164, 172, 199, and 230 (or “the first five motions”), Maxwell has illustrated the very problem that Plaintiff pointed out in the Original Parties’ April 30, 2020 joint letter to the Court. See ECF No. 1052. Because …
…Order and Protocol for Unsealing Decided Motions”) that, among other things, required that the original parties to the litigation use their best efforts to provide non- parties whose privacy, reputational, or other interests may be implicated by the unsealing of…
…that knowledge of who was objecting might aid the Court in “conducting future proceedings.” See DE 1100 (“Although [providing notice to all Non-Parties now] will give the Court and the Original Parties more information about the scope of objectors…
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