gov.uscourts.nysd.447706.972.0.pdf

Case 1:15-cv-07433-LAP Document 972 Filed 07/10/19 Page 1 of 1 Jay Marshall Wolman Licensed in CT, MA, NY, DC July 10, 2019 Via CM/ECF The Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433 Response to Letter Motion (Doc. No. 970) Dear Judge Preska, We represent Intervenor Michael Cernovich d/b/a Cernovich Media and oppose the letter- motion of Ms. Maxwell (Doc. No. 970) to adjourn the July 11 Conference. Although Ms. Giuffre opposed our efforts to unseal, we are pleased to join her in exposing these Jeffrey Epstein-related documents as quickly as possible. Thus, we object to the motion to adjourn. Your Honor is new to the case, and we want to ensure the Court is fully prepared to unseal the record without delay once the mandate issues. Though Ms. Maxwell is considering filing a petition for rehearing, we believe it highly unlikely such petition would be successful as the Second Circuit panel directly followed governing precedent. Ms. Maxwell otherwise appears to agree that the Court is authorized to hold the conference notwithstanding the pendency of the mandate. There should be no further artificial delay in unsealing the documents. Of the dates proposed, we are otherwise available August 6, 7, 14, 15, 16, and the morning of the 8th. Thank you for your attention to this matter. Sincerely, Jay Marshall Wolman Counsel for Intervenor Michael Cernovich 100 Pearl Street, 14th Floor, Hartford, Connecticut 06103 [email protected] | 702.420.2001