Maxwell Vs Giuffre update
LETTER addressed to Judge Loretta A. Preska from Sigrid S. McCawley dated October 1, 2020 re: Doe 1 & 2 objection to unsealing. Document filed by Virginia L. Giuffre.. Image
Plaintiff writes in response to Defendant’s letter dated September 30, 2020, seeking clarification from the Court regarding Doe 1 and Doe 2’s communication to the Court
Although Defendant did not propose a one-week extension of time
to object to the unsealing of the next set of Doe 1 and Doe 2 materials when conferring with Plaintiff, Plaintiff does not oppose that request provided that Plaintiff also receives a one-week extension
Plaintiff’s position is that when Doe 1 and Doe 2 emailed the Court, they filed their objection to unsealing, and the Original Parties therefore have 7 days to respond to that objection
or to file their own objection to unsealing the 5 motions at issue pursuant to the Protocol.
Doe 1 and Doe 2 chose to make that limited objection prior to receiving Excerpts, and although Plaintiff will happily send them Excerpts so
they have prior access to documents that may be released, they should not receive a second
opportunity to object thereafter Image
Allowing Non-Parties multiple opportunities to object to unsealing would set a precedent
that would exponentially delay this process.
though Plaintiff is sensitive to the fact that Doe 1 and Doe 2 are proceeding pro se, their communication indicates that they know the subject-matter of the documents that mention them, for example testimony in this case, and formulated their objection based on that understanding
Accordingly, Plaintiff seeks to move the Protocol forward, not delay it, but defers to the Court in how it believes the Original Parties should proceed.

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