…No.: 15-cv-07433-LAP GHISLAINE MAXWELL, Defendant. PROPOSED ORDER GRANTING THE MOTION TO WITHDRAW SANFORD BOHRER AS COUNSEL FOR INTERVENORS This matter having come before the Court by the filing of the Motion to Withdraw Sanford Bohrer as Counsel…
…respectfully submits this Motion to Compel Production of Documents For the reasons set forth below, this Court should grant Plaintiff’s Motion in its entirety. I. FACTUAL BACKGROUND1 1 Case 1:15-cv-07433-LAP Document 345 Filed 08/09…
…and 872]; and (b) all unfiled discovery deposition transcripts and exhibits thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted confidential access to these materials, and, if granted access, agrees to be bound…
…Dershowitz, Case No.: 19-cv-03377-LAP Your Honor: Professor Alan Dershowitz and Ms. Virginia Giuffre hereby jointly request that the Court grant them until January 5, 2021 to respond to the December 23, 2020 letter filed on behalf of…
…Dershowitz, Case No.: 19-cv-03377-LAP Your Honor: Professor Alan Dershowitz and Ms. Virginia Giuffre hereby jointly request that the Court grant them until January 5, 2021 to respond to the December 23, 2020 letter filed on behalf of…
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms. Giuffre’s motion should be granted. I. PRELIMINARY STATEMENT Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware, all of this…
…Giuffre. For the reasons set forth below, this Court should deny both of Defendant’s Letter Motions, and grant Professor Cassell and Mr. Edward’s Motions to Appear Pro Hac Vice. I. PROCEDURAL HISTORY Upon Defendant’s April 6, 2016…
…be served for his deposition will not prejudice the Defendant and will serve the search for truth. Ms. Giuffre’s motion should be granted. I. PRELIMINARY STATEMENT It is undisputed that Mr. Gow is a key witness in this case…
…party deposition is appropriate where important documents are produced after the deposition is completed. Accordingly, the Court should grant Ms. Giuffre’s request to reopen Defendant’s deposition to answer questions relating to her lately produced documents. I. BACKGROUND The…
…however, we would want to be afforded the opportunity to file an opposition to the Motion before it is decided. Accordingly, we respectfully request that the Court grant J Doe 12 permission, if necessary, to file an opposition to the…
…Lebowitz on behalf of Intervenor Alan M. Dershowitz. Dated: March 31, 2020 New York, New York KAUFMAN LIEB LEBOWITZ & FRICK LLP The motion to withdraw is granted. By: /s/ SO OR…
…Motion to Stay Discovery during the pendency of her Motion to Dismiss. LEGAL STANDARD Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to stay discovery “for good cause shown.” Spencer Trask Software and Info…
…18, and Motion to Compel Production of certain documents on Defendant’s Third Amended Privilege Log. For the reasons set forth below, this Court should grant Plaintiff’s Motion in its entirety. I. FACTUAL BACKGROUND1 1 On Wednesday, June 8…
…04 a.m., and to strike Defendant's affidavit, pleadings and grant attorney's fees to Virginia Roberts, and hereby states as follows. INTRODUCTION Alan Dershowitz intentionally and wrongfully submitted a misleading affidavit to this Court, kn…
…of non-public, on-going law enforcement investigations. Nor is there any good reason for the Court to grant a last-minute “stay” of this case (including Defendant’s long- delayed deposition, which is currently scheduled for Friday). Defendant has…
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms. Giuffre’s motion should be granted. I. PRELIMINARY STATEMENT Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware, all of this…
…and duly licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015 Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this Declaration in Support of Plaintiff’s Reply…
…Cassell, for admission to practice Pro Hac Vice in the above captioned action is granted. Applicant has declared that he is a member in good standing of the bar(s) and the state of Utah; and that his contact information…
…Partner with the law firm of Boies, Schiller & Flexner LLP and duly licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice. 2. I respectfully submit this…
…as Revised. The Court has carefully considered the Motion, and being otherwise fully advised in the premises, it is ORDERED AND ADJUDGED that the motion is hereby GRANTED. Plaintiff’s counsel, Sigrid S. McCawley shall be permitted, to bring and…