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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
rty 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
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
rty 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
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
rty 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
Entities connected to both Southern District and the Objecting Original Party

Ghislaine Maxwell
PERSONLaura Menninger
PERSON
Denver
LOCATION
Colorado
LOCATION
Foreman
PERSONLoretta A. Preska
PERSONthe Second Circuit's
ORGANIZATIONthe Criminal Action
ORGANIZATIONNon-Parties
ORGANIZATIONthe Non-Parties
ORGANIZATIONthe Original Parties
ORGANIZATIONthe Responding Original Party
ORGANIZATIONNext Set of Docket Entries
ORGANIZATION