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That is the definition. 24 However, I'm also going to ask the parties to agree 25 upon an order that would expand the confidentiality agreement SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00076418 Case 20-2413, Document 44. 08/20/2020, 2913556, Page37 of 78 App.-0811 7 G4LMGIUC 1 to this exte
cole Simmons 2 EFTA00076390 Case Gaga4.407741333-IDARn-Offiuhiefle3MOQIXD, Filki5B33fface9:4191;91 of 4 App.-0783 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
33-LAP Document 1100 Filed 08/10/20 Page 1 of 3 HADDON MORGAN FOREMAN August 10, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan and f
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
33-LAP Document 1100 Filed 08/10/20 Page 1 of 3 HADDON MORGAN FOREMAN August 10, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: August 3, 2020 Order (Doc. 1096) v. Ghislaine Maxwell, No. 15 Civ. 7433 (LAP) Haddon, Morgan
Court going forward, should the unsealing move ahead. Of note, and as Plaintiff will explain to the Court, the parties have agreed to notify all of the Non-Parties at once so that we can understand which Non-Parties object to the unsealing before deciding how to proceed with future redactions. Although this wil
Entities connected to both Southern District and the Non-Parties

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSONJeffrey Pagliuca
PERSONLaura Menninger
PERSON
Denver
LOCATION
Julie K. Brown
PERSONMaria Farmer
PERSONSigrid McCawley
PERSON
Colorado
LOCATION
Foreman
PERSON
the United States District Court
ORGANIZATIONHaddon
PERSONSecond Circuit
ORGANIZATIONSweet
PERSON
Russell Simmons
PERSONLoretta A. Preska
PERSON