…Doe 1 and J. Doe 2, as identified on the sealed Non-Party List, with which the Court may begin administering the Order and Protocol for Unsealing Decided Motions, Dkt. 1044. The Original Parties agree that the motion at Docket…
…NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, The Original Parties jointly write to seek clarification of the following parts of the Protocol for Unsealing Decided Motions, ECF No. 1044: at a time…
…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 THE COURT’S ORDER AMENDING THE UNSEALING PROTOCOL, DKT. 1230…
…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. …
…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 …
…to such nonparties’ specific conduct.” The rationale for redacting categories 2 and 3, implicit in the Court’s Order and Protocol for Unsealing Decided Motions, was to afford each Nonparty the opportunity for notice and the chance to be heard…
…interests by redacting the names and other identifying information of the non-parties. We further propose for the Court’s consideration a protocol to assist the Court in conducting its review. A. Judge Sweet Observed That The Sealed Materials Implicate…
…and (4) an interview of Plaintiff. Putting aside the fact that Doe 183 filed a 20-page objection in addition to an 8-page memorandum of law in violation of the Protocol, Doe 183’s objections should be overruled because…
…Court's time to entertain further briefing on 17 this issue, but that denial now would substantially protect the 18 ongoing unsealing review being conducted pursuant to the 19 protocol. To allow this litigation now to continue casts a 20…
…you our preliminary thoughts as to how to 9 proceed? And I will say that I am working off of Mr. Lewin's 10 revised proposed protocol. First of all, I think it must be 11 correct that you people…
…Cir. 2010) .....................................................................................................9 iii Case 1:15-cv-07433-LAP Document 1156 Filed 11/19/20 Page 5 of 19 Pursuant to Paragraph 2(f) of the Court’s Order and Protocol for …
…undercut their reasonable reliance on the Protective Order at the time they provided deposition testimony. See DE 1108 at (3)(f) (“A Non-Party’s participation in this protocol is optional. … Non-Parties are under no obligation to object…
…to the Federal Rules. Moreover, they were produced consistent with the ESI protocol agreed to between the parties in this action. Plaintiff wants to confirm where Defendant has searched for sources of ESI. Defense counsel has noted, to the Court…
…when we get to the trial. And 25 we have got to have some kind of a protocol as to how that's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 1332…
…when we get to the trial. And 25 we have got to have some kind of a protocol as to how that's SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-RWS Document 702…
…16 MR. LEWIN: Thank you, your Honor. If anything, this 17 entire discussion illustrates why the protocol we proposed is 18 right. If there are areas where the parties can agree, that 19 makes it easy. Moreover, we agree with…