dChan
Anonymous ID: 52a89e Jan. 4, 2024, 1:10 p.m. No.20183322   🗄️.is đź”—kun   >>3348 >>3368 >>3402

Giuffre v. Maxwell (1:15-cv-07433)

NEW FILING

 

Case 1:15-cv-07433-LAP Document 1321 Filed 01/04/24 Page 1 of 2

 

31 West 52nd Street | New York, NY 10019 | T | F 212.385.9010

Holland & Knight LLP | www.hklaw.com

Christine N. Walz

+1 212-513-3368

Christine.Walz@hklaw.com

January 4, 2024

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: LETTER MOTION TO UNSEAL DOCKET ENTRY 1026-3

Giuffre v. Maxwell, Case No. 15-cv-7433-LAP

Dear Judge Preska:

Intervenors Julie Brown and Miami Herald Media Company respectfully submit this

letter-motion to unseal (in part) Docket Entry 1026-3 to clarify how the assigned J. Doe

pseudonyms line up with the disclosed individuals in each of the unsealed docket entries, as well

as the Court’s reasoning associated with the same.

Docket Entry 1026-3 was submitted by counsel for Giuffre and Maxwell as part of the

unsealing protocol in this matter. It lists all the non-parties listed in any of the originally sealed

documents and was used by the Court to manage the unsealing process and make its

determinations about what information was to be unsealed. It is, therefore, a judicial document

subject to the public right of access. See United States v. Amodeo, 44 F.3d 141, 145 (2d Cir.

1995) (a filed document is a judicial document if it is “relevant to the performance of the judicial

function and useful in the judicial process.”).

Now that the Court has made all its rulings on the unsealing of documents (and as part of

that decision, is releasing the names of most non-parties), this document should be unsealed in

accordance with the Court’s decisions.

As a practical matter, the unsealing is garnering a significant amount of media coverage –

by Intervenors, other news organizations, and commentators on social media. Without this list,

Intervenors and the public are puzzling together the Court’s ruling with each of the unsealed

documents to match the identities of each of the third parties with the Court’s ruling. Many of the

documents contain references to multiple Does, which makes this more challenging.

 

January 4, 2024

Page 2

Releasing the complete list of names and pseudonyms will avoid spread of incorrect

information that may arise from trying to unweave the partial disclosures and will enable the

public and press to understand this Court’s reasoning.

For these reasons, Intervenors respectfully request that Docket Entry 1026-3 be unsealed.

Sincerely yours,

HOLLAND & KNIGHT LLP

/s/ Christine N. Walz

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

 

https://www.courtlistener.com/docket/4355835/giuffre-v-maxwell/?order_by=desc

 

Doc:

https://storage.courtlistener.com/recap/gov.uscourts.nysd.447706/gov.uscourts.nysd.447706.1321.0.pdf