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.447706.1227.0
2 pg
…2021, letter to the Court to correct
certain inaccuracies and to address certain criticisms of the Original Parties.
First, Doe criticizes the Original Parties’ compliance with the Court’s unsealing orders and
directives to redact the names of non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…above-captioned matter.
2. On August 26, 2020, the Court ordered the Original Parties to serve Non-Party
Notices on all remaining Non-Parties, ECF No. 1107, and the Original Parties agreed to split
responsibility for mailing the Non-Party…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. There Is Significant Overlap Between the Subject Matter
of the Original Action and This Motion ....................................................12
…
giuffre-maxwell
gov.uscourts.nysd.447706.1116.0
3 pg
…August 26, 2020 Order (Doc. #1107), directing the Original
Parties to serve Non-Party Notices on all remaining Non-Parties, as well as to Does 1 and 2 at
newly obtained addresses, and after conferral with Plaintiff’s counsel, undersigned…
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.447706.1115.0
4 pg
…in the above-captioned matter.
2. Pursuant to this Court’s August 26, 2020, order directing the Original Parties to serve
Non-Party Notices on all remaining Non-Parties, ECF No. 1107, the Original Parties
agreed to split responsibility for…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…as
news, as they are defamatory.”
Churcher is the sole source of information regarding the original story told by Plaintiff,
and was the author of the first articles publishing Plaintiff’s claims. She was actively and
personally involved in changing…
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.447706.1218.14
32 pg
…TO INTERVENE
UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11
A. There Is Significant Overlap Between the Subject Matter
of the Original Action and This Motion ....................................................12
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…``If a great network thinks it’s increasing its credibility by hiring a
convicted perjurer to tell us the truth, something’s wrong.’’
© 2015 Thomson Reuters. No claim to original U.S. Government Works. 1
Case 1:15…
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.447706.1160.0
1 pg
…the updated Order and Protocol for Unsealing Decided Motions (DE 1108), any
reply in support of an objection to unsealing filed by an Original Party is due “within 7 days
of service” of the opposition to such an objection. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1159.0_2
1 pg
…the updated Order and Protocol for Unsealing Decided Motions (DE 1108), any
reply in support of an objection to unsealing filed by an Original Party is due “within 7 days
of service” of the opposition to such an objection. Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…privileged document has been
identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The recent forensic imaging and searches have merely
confirmed as much. Plaintiff has sent defense counsel…
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.447706.1038.0
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.447706.1234.0
2 pg
…Non-Party Objection and accompanying memorandum, if any, the Original Parties
may file an opposition stating the reasons why any Sealed Item should be unsealed. The
opposition shall be served on the objecting Non-Party. The objecting Non-Party may…
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