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…
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…
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…
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1057.0
17 pg
…10th Avenue
Denver, CO 80203
303.831.7364
Case 1:15-cv-07433-LAP Document 1057 Filed 06/10/20 Page 2 of 17
Pursuant to this Court’s Order and p…
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…
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…
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…
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…
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…
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…
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…
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.
…
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…
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 …
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…
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…
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,
…
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…
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…