gov.uscourts.nysd.447706.183.0.pdf

Case Case 1:15-cv-07433-LAP 1:15-cv-07433-RWS Document Document183 177 Filed Filed06/01/16 05/31/16 Page Page1 1of1 of 1 B 0 I E S , S C H I L L E R & F L E X N E R L L P 40 1 EAST LAS OLAS BOULEVARD' SUiTE 200 •FORT LAUDERD.ALE , FL 3330! 22 •PH . 954 356 .00 1 •FAX 954 356.0022 Meredith L. Schultz, Esq . Email: [email protected] ViaCM/ECF Honorable Judge Robert W. Sw District Court Judge United States District Court 500 Pearl Street New York, NY I 0007 Re: Giuffre v. Maxwell, Case no. 15-cv-07433-R\VS - Regarding Protective Order Dear Judge Sweet: This is a letter motion to file Ms. Giuffre's Response in Opposition to Defendant's Motion to Compel Non-Privileged Documents and certain accompanying exhibits under seal pursuant to this Court's Protective Order (DE 62). The Protective Order states: Whenever a party seeks to file any document or material containing CONFIDENTIAL INFORMATION with the Court in this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. See Protective Order (DE 62) signed on March 17, 2016, at p. 4. Defendant has designated documents produced by Defendant as confidential. Ms. Giuffre takes no position at this time on whether Defendant's designations are proper. Because of the Protective Order, however, Ms. Giuffre believes that she cannot presently produce or reference such documents in public court filings. Accordingly. she seeks leave to file the Response and certain related exhibits under seal. Respectfully submitted, vVL-/.#-. cf?L~ Meredith L. Schultz, Esq. cc: Laura Menninger, via CM/ECF Jeffrey Pagliuca, via CM/ECF WWW BS F LLP.COM