giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…however, we here clarify that (1) the
judicial nature of a document is properly determined at the time it is filed
such that a motion that is a judicial document when filed does not cease to
be so because, before…
giuffre-maxwell
gov.uscourts.nysd.447706.551.0
17 pg
…B/A CERNOVICH MEDIA’S
MOTION TO INTERVENE AND UNSEAL
TABLE OF CONTENTS
TABLE OF AUTHORITIES ........................................................................................................ III
MEMORANDUM OF LAW ...............................................…
giuffre-maxwell
gov.uscourts.nysd.447706.79.2
18 pg
…34:A lld ocu ments reflectingyou rownershiporcontrolof property in
L ond on between the years 1999 and 20 0 2.
RESPONSE: M s.M ax wellobjects to this Requ estto the ex tentthatitcalls forthe
prod u ction of d ocu…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…Decided Motions
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…27__,
20202021)
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Decided Motions
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…27, 2020)
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1167.2
27 pg
…The Response and Exhibits were not referenced in the Order, and the exhibits are not properly
considered judicial documents.
2
Case 1:15-cv-07433-LAP Document 1167-2 Filed 12/01/20 Page 4 of 27
DATE
DOC. # …
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…today.” (Id. at 2.) On top of this--and despite the
Court’s instruction that the parties work together to ensure that
the materials were properly redacted by the appointed time--Ms.
Maxwell apparently has not provided to Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…The task can only be
properly accomplished with a thorough line-by-line review of each of the redactions
contained within the briefing papers and briefing-related papers.
It likewise is a substantial undertaking to identify even in summary fashion…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…LAP Document 1226 Filed 08/04/21 Page 2 of 4
August 4, 2021
Page 2 of 4
The second issue arises from the parties’ failure to properly make redactions …
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…1018
at 1 (concluding that “motions actually decided by Judge Sweet—along with documents relevant
to Judge Sweet’s decisions on those motions—are properly considered judicial documents to
which a presumption of public access attaches”).
As to the weight…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…2014) (holding that district court properly sealed contested documents “as they
reflected sensitive information about cooperating witnesses,” and concluding that sealing
Case 1:15-cv-07433-LAP Document 1020 Filed 01/17/20 Page 6 of 7
Honorable Loretta…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…s proposed redactions prior to filing, with no real help from
Maxwell “despite the Court’s instruction that the parties work together to ensure that the materials
were properly redacted by the appointed time.” Id. Plaintiff therefore rejects Maxwell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…614 (S.D.N.Y. 2000)). Such motions “are properly
granted only if there is a showing of: (1) an intervening change
in controlling law; (2) the availability of new evidence; or (3)
a need to correct a clear error…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…Defendant.
-------------------------------------------------X
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…properly
12 designated as such.
13 All of the documents that have been submitted in
14 connection with this case are highly sensitive confidential
15 documents that relate to very private matters of many
16 individuals.
17 Everyone associated with…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…Decided Motions
The Court previously ruled that “only motions actually decided by Judge Sweet—along
with documents relevant to Judge Sweet’s decisions on those motions—are properly considered
judicial documents to which a presumption of public access attaches.” Order…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…x 13, 16 (2d Cir. 2014) (holding that district court properly sealed contested
documents "as they reflected sensitive information about cooperating witnesses, “and concluding
that sealing was justified in part "to safeguard the privacy of individuals involved in an
investigation”;…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…the undecided
motions qualify as “judicial documents;” as the Second Circuit held, “a judicial document
determination is properly made by evaluating the relevant materials at the time of their filing with
the court.” Giuffre v. Maxwell, 146 F.4th 165…
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