giuffre-maxwell
gov.uscourts.nysd.447706.1242.0
9 pg
…in response to Plaintiff’s
opening brief. Pursuant to the Court’s November 15, 2021 Amended Order concerning the
briefing schedule for the Non-Party Objectors, Plaintiff Virginia Giuffre files this Reply Brief in
Response to Non-Parties 54, 55…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…Preska:
We write on behalf of an anonymous third party, John Doe, in advance of the conference
scheduled for tomorrow in the above-referenced matter. As this Court well knows, the July 3,
2019 Opinion of the United States Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…ii) clarify
whether it will accept and maintain as confidential additional
ex parte submissions in further support of her request to seal,
(iii) establish a schedule to address the issues related to the
sealing of documents pertaining to Doe 171…
giuffre-maxwell
gov.uscourts.nysd.447706.1134.0_5
2 pg
…order (ECF No. 1131), Plaintiff sent Maxwell
copies of her proposed redactions yesterday evening 2 and scheduled a telephone conference to
discuss those materials today. The parties met and conferred this afternoon, but could not reach
agreement on the materials…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…with the plaintiff and not with
10 me.
11 The problem I see, your Honor, is that now we are
12 scheduled to have expert disclosures due in July, dispositive
13 motions in August, and a trial date in October…
giuffre-maxwell
gov.uscourts.nysd.447706.461.0
2 pg
…to re-file
Dershowitz' s Reply Declaration with all references to paragraphs 20 and 21 of Mr. Cassell' s
declaration unredacted and not under seal. The hearing scheduled for Thursday, October 13,
2016, is hereby vacated.
It is so ordered.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…July 29,” (dkt. no. 1083 at 1),
Ms. Giuffre at a minimum gave the Court time to conduct a review
of her proposed redactions while preserving the original schedule
for unsealing. By contrast, Ms. Maxwell at 2:00 p.m…
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…release of Sealed Materials; (b) establishing a fixed schedule and procedure for both parties
and non-parties to promptly state their respective positions on the release of Sealed Materials,
including the opportunity to participate in an evidentiary hearing; and (c…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…Whenever that happens,
Plaintiff will be willing to negotiate (with both Maxwell and the Non-Party Objectors) a reasonable
schedule for preparing and filing the documents ordered to be released.
Case 1:15-cv-07433-LAP Document 1224 Filed…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…exhibits. Discovery is not yet complete. The criminal trial is scheduled to
commence July 12, 2021.
6
Case 1:15-cv-07433-LAP Document 1149 Filed 11/12/20 Page 8 of 18
The Constitution guarantees to Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…considered in which group. The pOriginal Parties will then endeavor
to give Notice to the particular eight objecting Non-Parties that their objections are to be
considered and the schedule pursuant to which briefing will occur. Within 7 days of…
giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…Maxwell during the district
court proceedings, both of whom have many other previously scheduled professional
obligations. We respectfully submit this work cannot be done short of 30 days.
We of course are aware of this Court’s and the Second…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…one month
prior to the commencement of trial. This action is currently
scheduled for trial in mid-May and a release of contested
confidential discovery materials could conceivably taint the
jury pool.
Further, there was "no viable basis to deny…
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