gov.uscourts.nysd.447706.925.0.pdf

.., Case 1:15-cv-07433-LAP Document 925 Filed 10/04/17 Page 1 of 2 Case 1:15-cv-07433-RWS Document 924 Filed 10/031 7 Page 1of2 Michael C. Miller 212 506 3955 [email protected] SteQtoe ST EP T OE S. JO HN SO N L LP 1114 Avenue of the Americas New York , NY 10036 212 506 3900 main www.steptoe.;c~9::m:::::~:=:=::::~:.:-· ,. USDC ~D uOCUM 1 ~ · a£.::TRO.i ( ' ... · DOC ,;· - -rx-- A VIA ECF llATE FILED: October 3, 2017 Hon. Robert W. Sweet U.S. District Judge United States District Court for the Southern District of New York 500 Pearl Street New York, New York 10007 Re: Giuffre v. Maxwell, 15-cv-7433-RWS - Regarding Protective Order Dear Judge Sweet: This is a letter motion, pursuant to this Court' s Protective Order (Dkt 62) and the Southern District of New York Electronic Case Filing Rules & Instru~tions 6.2, for leave to file under seal Proposed Intervenors Jeffrey Epstein's and Lesley Groff s ("Intcrvenors") Memorandum of Law in Support oflntervenors' Motion for Leave t Intervene and Modify the Protective Order (the "Motion to Modify"). For the reasons set forth in the Motion to Modify, Intervenors seek to modify the Protective Order in the Giuffre Matte in order to allow them to use evidence produced in the Giuffre Matter in support of a motion t~ dismiss another action against Intervenors, Jane Doe 43 v. Epstein, No. 17 Civ. 616, which is based on allegations similar to those made in the Giuffre Matter. The evidence at issue was produced by Jane Doe 43 , a non-party in the Giuffre Matter. Judge Koeltl, before whom the Ja~e Doe Matter is pending, instructed us to seek leave from this Court to modify the Protective Order in the Giuffre Matter. The Protective Order states: Whenever a party seeks to file any document or material con aining CONFIDENTIAL INFORMATION with the Court in this matter, it shall be ac ompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. r See Protective Order (Dkt 62) signed on March 17, 2016, at p. 4. In order to demonstrate to the Court why the Protective Order should be modified, Intervenos c: : : e :ep B~r us!J"1 ft:>· 3- 17 .. ' Case 1:15-cv-07433-LAP Document 925 Filed 10/04/17 Page 2 of 2 Case 1:15-cv-07433-RWS Document 924 Filed 10/031 7 Page 2 of 2 Hon. Robert W. Sweet STEPTOE I. JOUN SON LLP October 3, 2017 Page2 documents designated as Confidential Information in the Giuffre Mattej . Under the Protective Order, lntervenors cannot presently produce or reference Confidential Information in public th court filings . Accordingly, Intervenors seek leave to file their Motion Modify under seal. Respectfully submitted, I / &iLc/t;c;__ Michael C. Miller cc: All parties of record in the Giuffre Matter, via ECF Counsel for Jane Doe 43, via e-mail