giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…Rule 26 ............................................................................................................. 5
C. Plaintiff Cannot Base Alleged Lost Income on the Jobs of Others ....................... 6
D. Plaintiff Cannot Refuse to Provide Addresses and Telephone Numbers .............. 6
E. Plainti…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.2
70 pg
…babe!!! The book next...
See you tomorrow.
Hugs ,
s
XOxO
This e-mail and any attached files are intended for the named addressee
only. It contains information, which may be confidential and legally
privileged and also protected by copyright. Unless…
giuffre-maxwell
gov.uscourts.nysd.447706.1097.0_1
6 pg
…the
Court can review them in camera. Comments may be sent to the
Court’s email address at [email protected].
The Court specifically requests comment from counsel for John Doe
who has appeared in Maxwell. The Court will…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.9
4 pg
…com
/s/ J. Stanley Pottinger
J. Stanley Pottinger, Esq.
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by …
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…With Specificity, All Documents She
Is Withholding............................................................................................................4
B. Execution of Discovery Responses ............................................................................7
C. Ms. Giuffre Has Disclosed Her
giuffre-maxwell
gov.uscourts.nysd.447706.1090.44_1
3 pg
…UT 84112
(801) 585-5202 1
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.20
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.768.0
23 pg
…UT 84112
(801) 585-52022
2
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
19…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…that "this Court and other
3 courts have adopted the taking of deposition as the appropriate
4 mechanism to address late-disclosed witnesses." So your Honor,
5 we believe that this is the appropriate way to resolve any
6 prejudice…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.2
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.1
7 pg
…Doe #1, Doe #2, and Doe #3.
Provide the address or contact information for each Non-Party or his or her
legal counsel, which the Original Parties identified to the best of their ability.
2. Judicial Adjudication: Because of…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records ............................................ 5
D. Newly obtained education records and other witness testimony contradict Plaintiff’s
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.44
4 pg
…07/15/21 Page 3 of 4
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.229.6
24 pg
…84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…case. But Ms. Giuffre only recently learned
about this witness because Defendant fai led to properly disclose her months earlier. ln her
response, Defendant does not address the fact that Ms. Ransome and Ms. Maxwell know each
other. Indeed, Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.443.0
4 pg
…who made
multiple attempts to effect personal service upon Mr. Gow at both his business and residential
1
Case 1:15-cv-07433-LAP Document 443 Filed 09/22/16 Page 2 of 4
address.
On August 3, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1107.0
2 pg
…paragraph 2(b) of the Protocol
requires the Original Parties to use their “best efforts” to
provide notice to Non-Parties and specifically includes in
the definition of “best efforts” identifying the most current
address for a given Non-Party…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…Doe #1, Doe #2, and Doe #3.
Provide the address or contact information for each Non-Party or his or her legal
counsel, which the Original Parties identified to the best of their ability.
2. Judicial Adjudication: Because of…
giuffre-maxwell
gov.uscourts.nysd.447706.690.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…