gov.uscourts.nysd.447706.1102.0_1.pdf

Case 1:15-cv-07433-LAP Document 1102 Filed 08/12/20 Page 1 of 2 701 Brickell Avenue, Suite 3300 | Miami, FL 33131 | T | F 305.789.7799 Holland & Knight LLP | www.hklaw.com Sanford L. Bohrer +1 305-789-7678 [email protected] Christine N. Walz +1 305-789-7678 [email protected] August 12, 2020 Via ECF The Honorable Loretta A. Preska District Court Judge United States District Court for the Southern District of New York 500 Pearl Street New York, NY 10007 Re: INTERVENORS’ LETTER IN RESPONSE TO MAXWELL’S LETTER (DKT. 1100) Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska: Intervenors Julie Brown and Miami Herald Media Co. respectfully submit this letter in response to Ghislaine Maxwell’s letter dated August 10, 2020 (Dkt. 1100), in which she seeks a stay of the sealing process based on “critical new information.” Ms. Maxwell has made multiple efforts to stall this litigation and prevent the disclosure of documents to the public. Her August 10, 2020 letter is more of the same: It fails to offer a reasoned basis to support her request for a stay and instead says that the Court should trust her. This is wholly insufficient and the Court should deny Ms. Maxwell’s request. In addition to asking for a three-week stay, Ms. Maxwell also seeks to institute a blanket one-week stay of every unsealing decision by this Court, without offering any justification for doing so. (See Dkt. 1100, at 3.) The decision to grant a stay requires a case-by-case analysis; stays should not be incorporated into the unsealing process as a matter of right. Anchorage | Atlanta | Austin | Boston | Charlotte | Chicago | Dallas | Denver | Fort Lauderdale | Houston | Jacksonville | Lakeland Los Angeles | Miami | New York | Orlando | Philadelphia | Portland | San Francisco | Stamford | Tallahassee | Tampa | Tysons Washington, D.C. | West Palm Beach  Case 1:15-cv-07433-LAP Document 1102 Filed 08/12/20 Page 2 of 2 The Honorable Loretta A. Preska August 12, 2020 Page 2 Intervenors respectfully request that this Court deny Ms. Maxwell’s request for a three- week stay, as well as any other request by Ms. Maxwell to unnecessarily delay the unsealing of the records in this case. Sincerely yours, HOLLAND & KNIGHT LLP /s/ Christine N. Walz Sanford L. Bohrer Christine N. Walz 31 West 52nd Street New York, NY 10019 Telephone: 212.513.3200 Fax: 212.385.9010 Attorneys for Intervenors Julie Brown and Miami Herald Media Company