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Case 1:15-cv-07433-LAP Document 1100 Filed 08/10/20 Page 3 of 3

Honorable Loretta A. Preska
August 10, 2020
Page 3

providing the Notice to Doe 1 at the new address for any future pleadings that implicate his or her deposition, which is currently subject to the Second Circuit’s stay.

Third, to prevent against some of the errors that occurred during the last round of unsealings, we request that the Protocol be amended to require the Responding Original Party who proposes unsealing to supply with their Response a proposed unredacted set of the pleadings at issue, for the Court’s consideration and for the Objecting Original Party or Non-Party to have the right of reply. Preparing those redactions after the fact allows much ambiguity into the Court’s ruling and we believe the Court’s ruling should specify which redactions it is accepting or rejecting at the time of ruling.

Finally, we request that the Court allow for the any objecting Non-Party or Original Party be given 7 days following any unseal order to apply for relief in the Second Circuit from the order prior to the documents being released.

Proposed Next Set of Docket Entries for Review:

Given the Second Circuit’s stay concerning Ms. Maxwell and Doe 1’s deposition transcripts and materials that quote from them, we propose that the Court deviate from the Doe 1 and 2 chronology (given that Doe 1’s deposition is sprinkled throughout those motions) and instead take the following five decided motions and their related pleadings. This list represents the first five chronological decided motions that (a) have sealed or redacted materials and (b) do not have attached or quote from documents subject to the stay. They are:

• 75 – Defendant’s Motion to Compel Responses to Defendant’s First Set of Discovery Responses to Plaintiff

• 139 – Plaintiff’s Brief in Support of the Privilege Claimed for In Camera Submission

• 155 – Defendant’s Motion to Compel Non-Privileged Documents

• 215 – Sharon Churcher Motion to Quash Subpoena

• 231 – Defendant’s Motion to Reopen Deposition of Plaintiff Virginia Giuffre

Counsel for Ms. Maxwell is available for a telephone conference to discuss any of the foregoing, should the Court desire.

Respectfully submitted,

Laura A. Menninger

CC: Counsel of Record via ECF

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