Case 1:15-cv-07433-LAP Document 810 Filed 03/29/17 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x VIRGINIA L. GUIFFRE, Case No.: 15-cv-7433 (RWS) Plaintiff, -againstGHISLAINE MAXWELL, Defendant. : PROPOSED INTERVENOR MICHAEL : CERNOVICH D/B/A CERNOVICH : MEDIA'S OPPOSITION TO MOTION • TO STRIKE • • x Michael Cemovich ("Cemovich") d/b/a Cemovich Media ("Movant" or "Intervenor") hereby opposes Plaintiffs Motion to Exclude his Opposition [DE 763] to Plaintiff's ongoing efforts to shield judicial documents from media and public scrutiny.' Her latest argument is that Intervenor lacks standing to object to the redaction of a transcript of open-court proceedings in which his counsel participated, even sitting at counsels' table the entire time without objection.2 Plaintiff's citation to Esther Sadowsky Testamentary Tr. v. Fed. Hous. Fin. Agency, 412 F. Apply( 361 (2d Cir. 2011) is inapposite. In that matter, the motion to intervene had been denied, so the putative intervenor had no standing to contest collateral orders. Here, Intervenor's motion It must also be noted that there is no basis in the Federal Rules of Civil Procedure to "exclude" a filing. The motion was, however, docketed as a "motion to strike", though internally named a motion to "exclude". The closest applicable rule, Fed. R. Civ. P. 12(f), only applies to striking pleadings, not other filings, and it does not include lack of standing as a basis to strike. See Colony Ins. Co. v. Jack A. Halprin, Inc., No. 3:10 - CV - 1059 (CSH), 2012 U.S. Dist. LEXIS 95982, at *10-12 (D. Conn. July 11, 2012). Neither is Intervenor's objection an evidentiary document to which exclusion under the Federal Rules of Evidence might apply. 2 Plaintiff has not otherwise suggested that Intervenor is incorrect on the merits of his objection. As a result, it appears Plaintiff is seeking to redact matters beyond the personal identifiers listed in Fed. R. Civ. P. 5.2(a). Further, per Fed. R. Civ. P. 5.