gov.uscourts.nysd.447706.1213.1.pdf

Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 1 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 Docket Entry Plaintiff’s Position 345: Plaintiff’s Motion to Unseal and redact only names and identifying information of Non- Compel Production of Parties who have objected to unsealing or whose time to object to Documents Subject unsealing has not yet expired. to Improper Objection 344 Already public. 346 Unseal in full. Note: Original parties agree. 346-1 Unseal in full. Note: Original parties agree. Unseal and redact only names and identifying information of Non- 346-2 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 346-3 Unseal in full. Note: Original parties agree. 346-4 Unsealed by Second Circuit. Note: Original parties agree. Unseal and redact only names and identifying information of Non- 346-5 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 383 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 384 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 384-1 Unsealed by Second Circuit. Note: Original parties agree. Unseal and redact only names and identifying information of Non- 385 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 386 Unseal in full. Note: Original parties agree. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 387 Non-Party deponent (Doe 91) notice of unsealing, the Non-Party deponent requested excerpts, and the Non-Party deponent did not object to unsealing within two weeks of receiving the excerpts. Unseal and redact only names and identifying information of Non- 397 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 398 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 1  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 2 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 Unseal and redact only names and identifying information of Non- 398-1 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 398-2 Unseal in full. 398-3 Unseal in full. Note: Original parties agree. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 398-4 Non-Party deponent (Doe 1) notice of unsealing, the Non-Party deponent requested excerpts, and the Non-Party deponent did not object to unsealing within two weeks of receiving the excerpts. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 398-5 unsealing has not yet expired. The Original Parties sent the Non- Party deponent (Doe 7) notice of unsealing, and the Non-Party deponent did not request excerpts. 356: Plaintiff's Motion to Direct Defendant to Answer Adopt same ruling as DE 315 from second round of unsealing. Deposition Questions 357 Adopt same ruling as DE 316 from second round of unsealing. 357-1 Adopt same ruling as DE 316-1 from second round of unsealing. 357-2 Adopt same ruling as DE 316-2 from second round of unsealing. 357-3 Adopt same ruling as DE 316-3 from second round of unsealing. 357-4 Adopt same ruling as DE 316-4 from second round of unsealing. 357-5 Adopt same ruling as DE 316-5 from second round of unsealing. 357-6 Adopt same ruling as DE 316-6 from second round of unsealing. 357-7 Adopt same ruling as DE 316-7 from second round of unsealing. 357-8 Adopt same ruling as DE 316-8 from second round of unsealing. 367 Adopt same ruling as DE 316 from second round of unsealing. 367-1 Adopt same ruling as DE 316-1 from second round of unsealing. 367-2 Adopt same ruling as DE 316-2 from second round of unsealing. 367-3 Adopt same ruling as DE 316-3 from second round of unsealing. 367-4 Adopt same ruling as DE 316-4 from second round of unsealing. 367-5 Adopt same ruling as DE 316-5 from second round of unsealing. 367-6 Adopt same ruling as DE 316-6 from second round of unsealing. 2  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 3 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 367-7 Adopt same ruling as DE 316-7 from second round of unsealing. 367-8 Adopt same ruling as DE 316-8 from second round of unsealing. 368 Ruled on in second round of unsealing. 369 Ruled on in second round of unsealing. 369-1 Ruled on in second round of unsealing. 369-2 Ruled on in second round of unsealing. 369-3 Ruled on in second round of unsealing. 369-4 Ruled on in second round of unsealing. 369-5 Ruled on in second round of unsealing. 369-6 Ruled on in second round of unsealing. 369-7 Ruled on in second round of unsealing. 369-8 Ruled on in second round of unsealing. 369-9 Ruled on in second round of unsealing. 369-10 Ruled on in second round of unsealing. 369-11 Ruled on in second round of unsealing. 369-12 Ruled on in second round of unsealing. 369-13 Ruled on in second round of unsealing. 369-14 Ruled on in second round of unsealing. 369-15 Ruled on in second round of unsealing. 369-16 Ruled on in second round of unsealing. 362: Alan Dershowitz Motion to Intervene or Modify Already public. Protective Order Unseal and redact only names and identifying information of Non- 363 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 363-1 Unseal with Second Circuit redactions. 363-2 Unseal with Second Circuit redactions. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 363-7 unsealing has not yet expired. Unseal portions released by Second Circuit. 3 Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 4 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 Unseal and redact only names and identifying information of Non- 363-13 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 364 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 382 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 406 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 407 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 407-1 Unseal in full. 407-2 Unsealed by Second Circuit. Note: Original parties agree. 407-3 Unseal in full. Unseal and redact only names and identifying information of Non- 407-4 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 407-5 Unseal in full. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 407-6 Non-Party deponent (Doe 1) notice of unsealing, the Non-Party deponent requested excerpts, and the Non-Party deponent did not object to unsealing within two weeks of receiving the excerpts. Portion released by Second Circuit. 407-7 Unseal in full. Unseal and redact only names and identifying information of Non- 407-8 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: Doe is deceased. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 407-9 unsealing has not yet expired. The Original Parties sent the Non- Party deponents (Does 99, 122, & 136) notice of unsealing, and the Non-Party deponents did not request excerpts. Unseal article. For deposition, unseal and redact only names and identifying information of Non-Parties who have objected to 407-10 unsealing or whose time to object to unsealing has not yet expired. Note: The deponent is not on the Non-Party notification list because he is a law enforcement officer. 4 Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 5 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 407-11 Unseal in full. 407-12 Unseal in full. 407-13 Unseal in full. Note: Original parties agree. Unseal and redact only names and identifying information of Non- 407-14 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 407-15 Unseal in full. Unseal and redact only names and identifying information of Non- 407-16 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 407-17 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 407-18 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 407-19 Publicly available at DE 136. 407-20 Unseal in full. 407-21 Unseal in full. 407-22 Unseal in full. 407-23 Unseal in full. Unseal and redact only names and identifying information of Non- 408 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 408-1 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 408-2 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 408-3 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 408-4 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 435 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 435-1 Already public. 435-2 Already public. 5  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 6 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 435-3 Already public. 435-4 Already public. 435-5 Already public. 435-6 Already public. 435-7 Already public. 435-8 Already public. 435-9 Already public. 435-10 Already public. Unseal and redact only names and identifying information of Non- 436 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 444 Already public. 447 Unseal in full. 370: Defendant's Motion for Unseal and redact only names and identifying information of Non- Protective Order regarding Parties who have objected to unsealing or whose time to object to Financial Information unsealing has not yet expired. 371 Unseal in full. Unseal and redact only names and identifying information of Non- 371-3 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 388 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 389 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 389-1 unsealing has not yet expired. Note: The Original Parties sent the Non-Party deponent (Doe 160) excerpts, and the Non-Party deponent did not submit an objection. 389-2 Keep sealed pending resolution of Doe 151's objection. 6  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 7 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 389-3 Non-Party deponent (Doe 1) notice of unsealing, the Non-Party deponent requested excerpts, and the Non-Party deponent did not object to unsealing within two weeks of receiving the excerpts. The Second Circuit released this material. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 389-4 Non-Party deponent (Doe 67) notice of unsealing, and the Non-Party deponent did not request excerpts. The Second Circuit released this material. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 389-5 unsealing has not yet expired. Note: The deponent is not on the Non-Party notification list because he is a law enforcement officer. The Second Circuit released this material. 389-6 Unsealed by Second Circuit. Note: Original parties agree. This deposition transcript was unsealed on October 22, 2020, DE 1137-13. This document should be redacted in the same way as DE 389-7 1137-13, but the redactions of the names of Non-Parties whose time to object has expired should be removed. 389-8 Unseal in full. Unseal and redact only names and identifying information of Non- 389-9 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- 404 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 405 Unseal in full. Note: Original parties agree. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 405-1 unsealing has not yet expired. Redact phone numbers and email addresses. 422: Defendant's Motion to Compel Settlement Already public. Agreement 423 Already public. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 423-1 unsealing has not yet expired. Additionally, redact all phone numbers, email addresses, and personal addresses. 7  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 8 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 423-2 Unseal in full. Note: Original parties agree. 423-3 Already public. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 423-4 unsealing has not yet expired. Additionally, redact all phone numbers, email addresses, and personal addresses. 437 Already public. 468: Motion to Compel Ghislaine Maxwell to Produce Unseal and redact only names and identifying information of Non- Data from Undisclosed Email Parties who have objected to unsealing or whose time to object to Account and for an Adverse unsealing has not yet expired. Inference Instruction Unseal and redact only names and identifying information of Non- 469 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. Note: The Original Parties sent the 469-1 Non-Party deponent (Doe 1) notice of unsealing, the Non-Party deponent requested excerpts, and the Non-Party deponent did not object to unsealing within two weeks of receiving the excerpts. Unseal and redact only names and identifying information of Non- Parties who have objected to unsealing or whose time to object to 469-2 unsealing has not yet expired. The Original Parties sent the Non- Party deponent (Doe 7) notice of unsealing, and the Non-Party deponent did not request excerpts. This deposition transcript was unsealed on October 22, 2020, DE 1137-13. This document should be redacted in the same way as DE 469-3 1137-13, but the redactions of the names of Non-Parties whose time to object has expired should be removed. Unseal and redact only names and identifying information of Non- 479 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 480 Unseal in full. Note: Original parties agree. 480-1 Unseal but redact email addresses. 480-2 Unseal but redact email addresses. This deposition transcript was unsealed on October 22, 2020, DE 1137-13. This document should be redacted in the same way as DE 480-3 1137-13, but the redactions of the names of Non-Parties whose time to object has expired should be removed. 480-4 Unsealed by Second Circuit. Note: Original parties agree. 8  Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 9 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 Unseal and redact only names and identifying information of Non- 490 Parties who have objected to unsealing or whose time to object to unsealing has not yet expired. 491 Unseal in full. Note: Original parties agree. 491-1 Already public. 491-2 Unseal in full. Note: Original parties agree. 491-3 Unseal but redact email addresses. 491-4 Unseal but redact email addresses. 640: [Redacted] Motion for Keep sealed pending resolution of Doe 147’s objections. Protective Order 641 Keep sealed pending resolution of Doe 147’s objections. 641-1 Keep sealed pending resolution of Doe 147’s objections. 641-2 Keep sealed pending resolution of Doe 147’s objections. 655 Keep sealed pending resolution of Doe 147’s objections. 656 Keep sealed pending resolution of Doe 147’s objections. 656-1 Keep sealed pending resolution of Doe 147’s objections. 656-2 Keep sealed pending resolution of Doe 147’s objections. 656-3 Keep sealed pending resolution of Doe 147’s objections. 656-4 Keep sealed pending resolution of Doe 147’s objections. 656-5 Keep sealed pending resolution of Doe 147’s objections. 656-6 Keep sealed pending resolution of Doe 147’s objections. 656-7 Keep sealed pending resolution of Doe 147’s objections. 656-8 Keep sealed pending resolution of Doe 147’s objections. 656-9 Keep sealed pending resolution of Doe 147’s objections. 700 Keep sealed pending resolution of Doe 147’s objections. 701 Keep sealed pending resolution of Doe 147’s objections. 701-1 Keep sealed pending resolution of Doe 147’s objections. 701-2 Keep sealed pending resolution of Doe 147’s objections. 707 Keep sealed pending resolution of Doe 147’s objections. 709 Keep sealed pending resolution of Doe 147’s objections. 714 Keep sealed pending resolution of Doe 147’s objections. 9 Case 1:15-cv-07433-LAP Document 1213-1 Filed 02/12/21 Page 10 of 10 Exhibit A Plaintiff’s Position on Docket Entries 345, 356, 362, 370, 422, 468 & 640 715 Keep sealed pending resolution of Doe 147’s objections. 715-1 Keep sealed pending resolution of Doe 147’s objections. 715-2 Keep sealed pending resolution of Doe 147’s objections. 10