Found 26 results for “protocol” in 62ms

gov.uscourts.nysd.447706.1144.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1144.0 1 pg

…pursuant to the Court’s October 2, 2020 Order (dkt. no. 1125) and the Protocol (dkt. no. 1108), the original parties to this action may file their own objections to the unsealing of the materials served on Doe 1 no…

gov.uscourts.nysd.447706.1040.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1040.0 1 pg

…DE 1039, at 1; those submissions regarded additional changes to the protocol for notification of non-parties of the potential unsealing of certain filed documents. Non-party John Doe concurs with the modifications proposed by the defendant, for the reasons…

gov.uscourts.nysd.447706.1264.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1264.0 1 pg

…DE 1258, at 1. The Court should deny TGP’s motion to intervene and unseal. This Court has implemented a carefully calibrated unsealing protocol that advances Your Honor’s individualized review of each sealed docket entry. See e.g., DEs…

gov.uscourts.nysd.447706.1054.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1054.0 1 pg

…Sigrid S. McCawley, do hereby certify that on May 11, 2020, pursuant to the Court’s Protocol for Unsealing Decided Motions, ECF No. 1044, I served J. Doe 1 with the following documents by first class certified mail with a…

gov.uscourts.nysd.447706.1055.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1055.0 1 pg

…Sigrid S. McCawley, do hereby certify that on May 11, 2020, pursuant to the Court’s Protocol for Unsealing Decided Motions, ECF No. 1044, I served J. Doe 2 with the following documents by first class certified mail with a…

gov.uscourts.nysd.447706.1105.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1105.0 8 pg

…Court regarding unsealing, the Court’s protocol and legal precedent dictate that the absence of such participation should not factor negatively into the Court’s balancing of considerations – as it is ultimately the responsibility of this Court, and not the…

gov.uscourts.nysd.447706.1073.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1073.0 22 pg

…unjustified obstacles” or that the public will never have access to these documents -- reflect unjustified criticisms of the Protocol itself and the Second Circuit’s decision in Brown, both of which fairly outline the legal process for parties and Non…

gov.uscourts.nysd.447706.1238.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1238.0 1 pg

…who have ably asserted their own respective privacy rights. Ms. Maxwell therefore leaves it to this Court to conduct the appropriate review consistent with the Order and Protocol for Unsealing Decided Motions. Dkt. 1108 at 5 ("The Court will conduct…

gov.uscourts.nysd.447706.1160.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1160.0 1 pg

…2020. Counsel for plaintiff does not object to the extension. Under 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…

gov.uscourts.nysd.447706.1159.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1159.0_2 1 pg

…2020. Counsel for plaintiff does not object to the extension. Under 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…

gov.uscourts.nysd.447706.1192.0_3.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1192.0_3 3 pg

…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…

gov.uscourts.nysd.447706.1062.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1062.0 7 pg

…to produce “all filings and discovery materials, including third-party discovery,” from Maxwell, including documents governed by the Maxwell Protective Order and sealed materials (the “Sealed Documents”) presently under review by this Court pursuant to the agreed-upon protocol. Id. …

gov.uscourts.nysd.447706.1047.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1047.0 2 pg

…and pleadings associated with that [Doe].” (Dkt. no. 1045 at 2.) To the extent that this requires substantive changes to the March 31, 2020 Protocol and attached Notices, (dkt. no. 1044), the parties shall submit updated versions by no later…

gov.uscourts.nysd.447706.1234.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1234.0 2 pg

…themselves may respond to the parties’ briefs, even though the unsealing protocol itself specifically provides that objecting non-parties may file a reply in support of their objections within seven days of service of the parties’ briefing. See DE 1108 …

gov.uscourts.nysd.447706.1354.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1354.0 7 pg

…at 180–82. 1. Undecided Motions1 Plaintiff’s Position: Mindful of the Court’s directive that “the parties’ proposals should accord with the Unsealing Protocol previously issued by this Court, including with respect to identification and notification of any affected…

gov.uscourts.nysd.447706.965.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.965.0 9 pg

…s, 14 and was dismissed shortly thereafter. Two times since May we 15 have asked for agreed upon protocol with the plaintiff's 16 counsel to finish up destroying or exchanging-back confidential 17 documents. The first request was shortly…

gov.uscourts.nysd.447706.1033.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1033.0 1 pg

…and they should be considered in the Court’s initial unsealing protocol. Plaintiff requests leave to file the List of Decided Motions under seal as it contains information about documents that are currently under seal or redacted. Sincerely, …

gov.uscourts.nysd.447706.13.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.13.0 1 pg

…order to the defendant(s) on or before the completion of discovery. The parties are advised that this Court is participating in a Pilot Program for initial discovery protocols for employment cases alleging adverse action. See www.fjc.gov. 3…

gov.uscourts.nysd.447706.363.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.9 5 pg

…2001 and January 1, 2003. Based upon my experience and knowledge of the duties, protocols and operations of USSS Protective Details, the Special Agents accompany and escort former President Clinton 24 hours per day, and would have certainly went with…

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