gov.uscourts.nysd.447706.1264.0.pdf

Case 1:15-cv-07433-LAP Document 1264 Filed 08/08/22 Page 1 of 1 August 8, 2022 By ECF The Honorable Loretta A. Preska United States District Judge Southern District of New York 500 Pearl Street, Room 2220 New York, NY 10007-1312 Re: Giuffre v. Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We write on behalf of non-party John Doe in response to Movant-Intervenor TGP Communications, LLC, d/b/a The Gateway Pundit’s (“TGP’s”) motion to intervene and unseal materials. See DEs 1258–59. TGP seeks to intervene for the purpose of moving to unseal and make public a hypothetical set of documents that TGP speculates identify a group of non-parties in this action who allegedly “abused girls trafficked by Jeffrey Epstein and Defendant Maxwell.” See DE 1258, at 1. The Court should deny TGP’s motion to intervene and unseal. This Court has implemented a carefully calibrated unsealing protocol that advances Your Honor’s individualized review of each sealed docket entry. See e.g., DEs 1034, 1044, 1053, 1108, 1157, 1230. That protocol, which was first put in place more than two years ago, balances the presumption of public access to judicial documents against the privacy, reputational, and other countervailing interests that support the continued sealing of certain of the previously sealed materials in this case. See id. TGP’s motion seeks to discard this protocol and thwart its carefully calibrated process and objectives. And the motion offers no reason to do that. To the contrary, it merely rehashes certain arguments, conjecture, and hyperbole that have been previously asserted in various efforts to unseal the docket in this case, and that the Court has fully considered and rejected. TGP’s brief fails to point to any new facts, circumstances, or changes in the law or even this case that warrant the Court’s deviation from the process that it previously set out and to which the Court, the parties, and non-parties have endeavored to adhere. Accordingly, TGP’s request to intervene and unseal should be denied. Respectfully Submitted, KRIEGER KIM & LEWIN LLP By: _________________________ Nicholas J. Lewin Paul M. Krieger cc (by ECF): Maxwell Counsel of Record (15 Civ. 7433 (LAP))