giuffre-maxwell
gov.uscourts.nysd.447706.1084.0
1 pg
…I emailed Ms. Menninger requesting a copy of the unredacted
letter so that we could respond to her objections to our proposed redactions. We have not yet
received those materials so I am not able to comment on them except…
giuffre-maxwell
gov.uscourts.nysd.447706.1086.0
1 pg
…No. 15-cv-7433-LAP
Dear Judge Preska,
As a follow up to my letter from earlier today, we are now in receipt of the unredacted
version of Ms. Menninger’s letter alleging that we made errors in our redactions…
giuffre-maxwell
gov.uscourts.nysd.447706.461.0
2 pg
…file
Dershowitz' s Reply Declaration with all references to paragraphs 20 and 21 of Mr. Cassell' s
declaration unredacted and not under seal.
Proposed Intervenor Alan M. Dershowitz' s Motion to re-file Dershowitz' s Reply
Declaration with all references…
giuffre-maxwell
gov.uscourts.nysd.447706.1085.0
1 pg
…in her July 30, 2020 letter. DE 1083.
Plaintiff intends to file the redacted version of the letter publicly on ECF and seeks leave only to
file the unredacted version under seal.
Sincerely,
/s/ Sigrid S. McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.1075.0
1 pg
…the Court finds that sealing would protect
July 1, 2020 confidential information, Counsel’s request to
file the unredacted reply papers and the exhibits
Honorable Loretta A. Preska thereto under seal is granted. SO ORDERED.
United States District Court
Southern…
giuffre-maxwell
gov.uscourts.nysd.447706.1236.0
1 pg
…Plaintiff has redacted that information pending disposition of the non-party objections.
Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks leave only to
file the unredacted version under seal.
Sincerely,
/s/ Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1311.0
1 pg
…has redacted that information pending disposition of the non-party
objections. Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks
leave only to file the unredacted version under seal.
Sincerely,
/s/ Sigrid S. …
giuffre-maxwell
gov.uscourts.nysd.447706.1148.0
1 pg
…materials remain under seal.
Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and
seeks leave only to file the unredacted version and Exhibit D under seal.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of…
giuffre-maxwell
gov.uscourts.nysd.447706.1168.0_2
2 pg
…s
request that these materials remain under seal.
Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and
seeks leave only to file the unredacted version and Exhibit E under seal.
Ms. Maxwell additionally requests…
giuffre-maxwell
gov.uscourts.nysd.447706.1082.0
1 pg
…York.
Doc. # 62 at 4. The Letter to the Court and the proposed unredactions contain information
deemed CONFIDENTIAL by the parties pursuant to the Protective Order. References to and
discussion of specific CONFIDENTIAL materials are necessary to support Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1072.0
1 pg
…remain under seal.
Ms. Maxwell intends to file the redacted version of the Reply publicly on ECF and seeks
leave only to file the unredacted version and Exhibits A-D under seal.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of…
giuffre-maxwell
gov.uscourts.nysd.447706.1152.0
1 pg
…materials remain under seal.
Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and
seeks leave only to file the unredacted version and Exhibit D under seal.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…onparties,
including alleged victims.” (Id.) Ms. Giuffre suggests in her
response that any unredacted nonparty names may have already been
released by the Court of Appeals, but otherwise acknowledges that
it is possible there were errors in her proposed redactions…
giuffre-maxwell
gov.uscourts.nysd.447706.1195.0_2
2 pg
…Intervenors do not have access to the unredacted letter and can only understand the
contents based on the context surrounding the redactions.
Anchorage | Atlanta | Austin | Boston | Charlotte | Chicago | Dallas | Denver | Fort Lauderdale…
giuffre-maxwell
gov.uscourts.nysd.447706.1244.0
1 pg
…has redacted that information pending disposition of the non-party
objections. Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks
leave only to file the unredacted version under seal.
Sincerely,
/s/ Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1246.0
1 pg
…has redacted that information pending disposition of the non-party
objections. Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks
leave only to file the unredacted version under seal.
Sincerely,
/s/ Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…list. And each time the Court makes a ruling, it
would be ruling only on whether the names of two Does should be unsealed or unredacted in a
particular set of documents. That is inconsistent with Paragraph 2(j). And…
giuffre-maxwell
gov.uscourts.nysd.447706.1241.0
1 pg
…has redacted that information pending disposition of the non-party
objections. Plaintiff intends to file the redacted version of the brief publicly on ECF and seeks
leave only to file the unredacted version under seal.
Sincerely,
/s/ Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1165.0_1
2 pg
…s
request that these materials remain under seal.
Ms. Maxwell intends to file the redacted version of the Memorandum publicly on ECF and
seeks leave only to file the unredacted version and Exhibit E under seal.
Ms. Maxwell additionally requests…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…answers to “personal”
or “embarrassing” questions. Pages 2 through 8 of Docket Entry 172 should therefore be
unredacted.
If the Court declines to unseal pages 2 through 8 in full, the following items in Docket
Entry 172 summarize portions of…
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