## UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

Case No. 0:16-mc-61262-JEM

In re: SUBPOENA TO

J.

Underlying Case:

Plaintiff

v.

GHISLA1NE MAXWELL,

Defendant

No. 15-cv-07433-RWS (S.D.N.Y)

I

## MOTION TO SEAL MOTION TO QUASH SUBPOENA OR, IN THE ALTERNATIVE, FOR A PROTECTIVE ORDER

Subpoena respondent J. . a non-party and attorney for the plaintiff in the v. Maxwell action, hereby files this motion for leave to file materials under seal for his reply in support of his motion to quash.

In his reply to his motion for to quash subpoena, attached eight exhibits. Five of these exhibits contain a document that is under seal in another court, specifically:

- I. Exhibit I Victims Response to Dershowitz Motion to Intervene, under seal in the U.S. District Court for the Southern District of Florida;

2. Exhibit 3 - Motion for Leave to Exceed the Presumptive Ten Deposition Limit, the salient portions of which (i.e., the portions relied upon in this case) are under seal in the underlying case in U.S. District Court for the Southern District of New York;

1. Exhibit 4— Excerpts from the Confidential Deposition of Ghislaine Maxwell, which is under seal in the underlying case in U.S. District Court for the Southern District of New York;

1. Exhibit 5 - Excerpts from the Confidential Deposition of Rinaldo Rizzo, which is under seal in the underlying case in U.S. District Court for the Southern District of New York; and

1. Exhibit 6 — The Opinion of the U.S. District Court for the Southern District of New York (Sweet, J.) in v. Maxwell, June 20, 2016, which is under seal in the underlying case in the U.S. District Court for the Southern District of New York.

In addition, portions of the reply memorandum itself quote from or refer to the sealed materials. Accordingly, a redacted version of the reply memorandum has been prepared for inclusion in the public court file, which avoid disclosing the sealed information.

Because the indicated materials are under seal by order of other federal courts, seeks leave to file these materials under seal here. has followed the procedures of the Southern District of Florida for the handling of sealed materials.

Opposing counsel has simply filed similar materials in this case under seal without seeking leave of court. Accordingly, believes that opposing counsel would have no objection to his filing of similar materials under seal. Because believes that a motion is required for a sealed filing, he proceeds by way of motion to this Court.

## CONCLUSION

For the forgoing reasons, respectfully requests that this Court allow him to submit materials under seal in his reply memorandum supporting his motion to quash.

Dated: July 7, 2016

Respectfully Submitted,

Is, Jack Scarola

Jack Scarola

Florida Bar No.: 169440

Attorney E-Mail(s): jsx@searcylaw.com and mep@searcylaw.com

Primary E-Mail: \_scarolateam@searcylaw.com

Searcy Denney Scarola Barnhart & Shipley, P.A.

2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409

Phone: (561) 686-6300

Fax: (561) 383-9451

Attorney for non- arty respondent

J.

## CERTIFICATE OF SERVICE

I certify that on July 7, 2016, I electrically served the foregoing pleading via the Court's CM/ECF filing system on:

Laura A. Menninger

Jeffrey SAila

Haddon, and P.C.

150 East 101 Avenue

Denver, CO 80203

Phone: (303) 831-7364

Fax: (303) 832-2628

Imenninger@hmflaw.com

Attorneys for Ghislaine Maxwell