…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…
…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…
…Non-Party Notices to J. Doe 1 through J. Doe 92. 3. Pursuant to the Order and Protocol for Unsealing Decided Motions (Doc. # 1108), I used best efforts to obtain the most current addresses for J. Does 1 through J…
…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…
…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…
…this issue, Plaintiff’s newfound characterization of this case as complex is disingenuous at best. It is also disingenuous for Plaintiff to claim that she in good faith attempted to negotiate a protocol for searching electronically stored information (“ESI”). On…
…4610422, at *7 (S.D.N.Y. July 23, 2015) (Sweet, J.) (ordering that “the parties shall meet and confer in order to set a[n electronic] search protocol”). A case need not be designated “complex” for Fed. R. Civ…
…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, …