gov.uscourts.nysd.447706.125.0.pdf

Case 1:15-cv-07433-RWS Document 120 Filed 04/25/16 Page 1of1 B 0 I E S. S C H I L L E R & F L E X N E R L L P 40! EAST LAS OLAS BOULEVARD• SUITE 1200 • FORT LAUDERD.ALE , FL 3330i 2 21 i • PH 954 .356.00 1 • FAX 954.356.002 2 Sigrid S. Mccawley, Esq. Email: [email protected] April 25, 2016 .. ' .... Via CM/ECF ~ Re: Giuffre v. Maxwe , Case no. 15-cv-07433-RWS - Regarding Protective Order Dear Judge Sweet: This is a letter motion to file Ms. Giuffre's Non-Redacted Reply in Support of Motion for Forensic Examination ("Reply Brief') and certain accompanying exhibits under seal pursuant to this Court's March 18, 2016, Protective Order and the Southern District of New York Electronic Case Filing Rules & Instructions 6.2. 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. Defendants have designated certain documents as Confidential Information and have designated Defendant's entire deposition testimony 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, as Ms. Giuffre' s Reply Brief contains material that Defendant has designated as confidential, she seeks leave to file the Non-Redacted Reply Brief and certain related exhibits under seal. Respectfully submitted, ~~ ,/ /;ig~ Mc;:~. cc: Laura Menninger via CM/ECF WWW BSFLLP .COM