UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT Thurgood Marshall U.S. Courthouse 40 Foley Square, New York, NY 10007 Telephone: 212-857-8500 MOTION INFORMATION STATEMENT Docket Number(s): 10-2905-cr; 11-479-cr Caption [use short title] Motion for: intervening and unsealing docket Roe v. United States 10-2905-cr, 11-470-cr Set forth below precise, complete statement of relief sought: This is a motion to intervene. Intervenor moves to: (1) intervene; (2) unseal the entirety of the Second Circuit's docket; and (3) unseal all docket entries. MOVING PARTY: Forbes Media LLC and Richard Behar OPPOSING PARTY: 9 Plaintiff 9 Defendant 9 Appellant/Petitioner 9 Appellee/Respondent MOVING ATTORNEY: Jay Ward Brown OPPOSING ATTORNEY: [name of attorney, with firm, address, phone number and e-mail] Levine Sullivan Koch & Schulz, L.L.P. Phone: (202) 508-1136 1899 L Street, NW, Suite 200 Email:
[email protected] Washington, D.C. 20036 Court-Judge/Agency appealed from: N/A (The proceedings below occurred in the district court for the E.D.N.Y.) Please check appropriate boxes: FOR EMERGENCY MOTIONS, MOTIONS FOR STAYS AND INJUNCTIONS PENDING APPEAL: Has movant notified opposing counsel (required by Local Rule 27.1): Has request for relief been made below? 9 Yes 9 No ✔9 Yes 9 No (explain): Has this relief been previously sought in this Court? 9 Yes 9 No Requested return date and explanation of emergency: Opposing counsel’s position on motion: ✔9 Unopposed ✔ 9 Opposed 9 Don’t Know Note regarding opposing counsel's position: Does opposing counsel intend to file a response: ✔9 Yes 9 No 9 Don’t Know the United States counsel does not oppose standing, but does oppose unsealing; Doe's counsel did not respond after being notified of the motion.