…privacy, and (3) requesting excerpts of sealed materials that mention them for their review (the “September 25 Email”). The parties dispute the procedural import of the September 25 Email under the Protocol governing the unsealing of documents in this action…
…letters to the Court dated November 10, 2020 (DE 1143) and November 16, 2020 (DE 1153) concerning various issues surrounding the unsealing protocol. In the final paragraph of her November 10, 2020 correspondence, Plaintiff asserts her belief that the Court…
…1096. As to streamlining the process, the parties have agreed upon the following changes to the Protocol: First, to speed up the unsealing process and to minimize the number of Non-Party names that need to be redacted from future…
…2020 (see dkt. no. 1154 (“Def. Letter”)), addressing (1) their respective interpretations of certain aspects of the unsealing protocol (Order and Protocol for Unsealing Decided Motions, dated Aug. 27, 2020 (“Protocol”) [dkt. no. 1108]) that concern (a) the effect of…
…to the Court’s July 1, 2021, direction that the Parties meet and confer and propose to the Court ways to streamline the present unsealing process, as detailed in the Unsealing Protocol. ECF No. 1108. The Parties met and conferred…
…The Honorable Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: INTERVENORS’ LETTER REGARDING REVISIONS TO THE UNSEALING PROTOCOL Giuffre v. Maxwell, Case No…
…2020 Order (Dkt. 1034), Plaintiff’s counsel and Defendant’s counsel have conferred about the Court’s proposed Protocol. Plaintiff agrees to the Court’s Protocol as written, including the Court’s proposal to review documents by Non-Party in…
…September 30, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Doe 1 & 2 Request for Excerpts and Updated Protocol (Doc. # 1108) Giuffre v. Ghislaine Maxwell, No…
…District Judge: The Court has considered the parties’ submissions concerning (1) the next steps in the Court’s individualized review of the sealed materials and (2) suggestions for updating the Order and Protocol for Unsealing Decided Motions (the “Protocol,” dkt…
…John Doe, in response to the letters filed by the parties in the above-referenced case offering competing proposals for streamlining the unsealing process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224. We write to…
…the Non-Party List, and Ms. Maxwell’s proposed Order and Protocol. List of Decided Motions. Plaintiff’s only objection to the use of Doc.1007-1 as the List of Decided Motions is her position that two motions, Docs…
…Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: INTERVENORS’ LETTER IN RESPONSE TO DOE’S LETTERS REGARDING THE UNSEALING PROTOCOL (DKT. NOS. 1226…
…Court’s August 26 and 27, 2020, orders regarding the next steps in the Court’s individualized review of the sealed materials, and deadlines set forth in the Order and Protocol for Unsealing Decided Motions (the “Protocol”). Dkts. 1107, 1108. …
…Plaintiff’s letter of August 5, 2021, see DE 1227. Our letter of August 4, 2021 suggested several proposals to help expedite the continued implementation of the Protocol and the particularized review contemplated for each non-party. It appears, however…
…28, 2021, order directing the Parties to “submit a revised version of the protocol” and “a briefing schedule to address the objections of the first eight non-party objectors.” ECF No. 1230 at 3. Plaintiff’s Position On October 5…
…Court’s review of documents in which the public has an interest. Defendant’s first proposal below will not make the Protocol more efficient for the reasons outlined above. Defendant’s second proposal will require changes to the Protocol because…
…please, when you 2 speak to say your name first so that the court reporter is able 3 to do a good transcript. 4 We have looked at your various letters regarding the 5 protocol, and with respect to paragraph…
…Doe 1 and Doe 2’s objection to unsealing. As background, on May 15, 2020, Plaintiff served Doe 1 and Doe 2 with a Non-Party Notice by first class certified mail pursuant to the Protocol. ECF Nos. 1054, 1055…
…seeking access to sealed materials beyond what was unsealed by the Second Circuit, the carefully constructed protocol established by this Court remains the appropriate mechanism for resolving all such access issues for judicial records. This Court will ultimately determine what…
…from Maxwell (the “Sealed Materials”) should be publicly released. We write to request that the Court protect the integrity of the Protocol in Maxwell (the “Protocol”) against these evasions; the Court should deny the Dershowitz parties’ request for a list…