giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…982. The parties met and conferred several times over the past two weeks,
and were able to reach agreement with the exceptions of Categories 4 and 10 below. Plaintiff
believes that all documents concerning trial deposition designations (including objections and…
giuffre-maxwell
gov.uscourts.nysd.447706.434.0
1 pg
…2016, the Court issues a ruling on Cassell's motion to quash and
directed the parties to meet and confer within two weeks as to whether any redaction
were required in the Court's opinion before it was made public…
giuffre-maxwell
gov.uscourts.nysd.447706.264.0
3 pg
…with that Order. The parties are
further directed to jointly file a proposed redacted version of this Opinion or Notify the
Court that none are necessary within two weeks of the date of receipt of this Opinion.
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1213.1
10 pg
…and the Non-Party deponent did not
object to unsealing within two weeks of receiving the excerpts.
Unseal and redact only names and identifying information of Non-
397 Parties who have objected to unsealing or whose time to object to…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
… We can have a piece of that to the
15 Court in about two weeks.
16 The most time-consuming piece is the deposition
17 transcripts so that will take us a little bit longer but that
18 would be…
giuffre-maxwell
gov.uscourts.nysd.447706.1220.0
17 pg
…prepare the documents for unsealing pursuant to the findings
13 just made. This is not an exercise that needs to be undertaken
14 on the long Independence Day weekend, so nobody has to start
15 until after the end of…
giuffre-maxwell
gov.uscourts.nysd.447706.1294.0
11 pg
…18, 2022, the Herald to file a
responsive brief two weeks later, the objecting Non-Parties to
file a reply in response to the parties’ and the Herald’s briefs
a week after the Herald filed its responsive brief, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…Maxwell for nearly six years have two
other major, multiple-week trials scheduled for almost the entirety of September and October 2021.
Practically speaking, the entire Maxwell team have scant time outside of a courtroom in the coming
months and…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…2020, including the
release of Ms. Maxwell’s April 2016 deposition, generated over 390 internet news stories in the
days and weeks following the unsealing. See Ex. C. One of the articles from NPR article quoted
line by line various…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.1
16 pg
…Non-Party deponent requested excerpts,
and the Non-Party deponent did not object to unsealing within two
weeks of receiving the excerpts.
Unseal and redact only names and identifying information of
340-8 Non-Parties who have objected to unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1351.0
32 pg
…No. 15-cv-7433, 2023 WL 8715697 (S.D.N.Y.
Dec. 18, 2023). Approximately two weeks later, on January 5, 2024, the
district court issued a further order denying the Herald’s and Intervenor
7 See, e.g., Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.980.0
10 pg
…enters the public record.
Brown, 929 F.3d at 47 (internal quotation omitted).
The media coverage over the course of the previous weeks bears out – powerfully – the
concerns expressed by the Court of Appeals. A review of media reporting from…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…Non-Parties at a time, and then notifying the next 30 Non-Parties two weeks after submitting
affidavits of service.
But Plaintiff does not believe that the Court intended the piecemeal approach that
Defendant suggests, and instead intended to rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…counsel for Ms. Maxwell proposed that any Omnibus brief be
completed two weeks after the completion of the criminal trial. At the time counsel conferred,
Judge Nathan had not yet announced her views as to the anticipated length of the…
giuffre-maxwell
gov.uscourts.nysd.447706.892.0
11 pg
…involving allegations of sexual abuse and
trafficking of minors, and because we are mere weeks from
assembling a jury for trial , the importance of leaving these
materials protected by the Protect i ve Order outweighs any public
interest in their…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.0
16 pg
…March 31st or Friday April 3rd at 1:00,
2:00 or 4:00 EST. Counsel also has availability the following week if the Court would prefer.
Respectfully submitted,
Laura A. Menninger
CC: Counsel of Record via ECF
Case…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…a claimed victim of this crime.
x August 3, 2001 – Plaintiff (then a week shy of her 18th birthday) called police
regarding a theft of cash from her shirt pocket in her apartment, during a party
she was hosting there…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…you did last
12 time, confer, and prepare the documents for unsealing pursuant
13 to this order, and post the documents within a week on the
14 public docket. As before, give them an appropriate name, such
15 as documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1099.0
4 pg
…in favor of public access to the records of judicial proceedings.”).
Fourth, Maxwell proposed providing a one-week window in the Protocol for filing an
appeal as to any ruling before documents are released. Plaintiff rejects this proposal as well…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…Once it is challenged, we have a ten-day
19 window to file something with the Court. So we filed our
20 motion for the protective order.
21 On Friday of this past week, on the 17th, they issued
22…
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