giuffre-maxwell
gov.uscourts.nysd.447706.1010.0
3 pg
…2019
Honorable Loretta A. Preska
United States District Court
Southern District of New York
500 Pearl Street
New York, NY 10007
Re: Defendant Maxwell’s Request for Clarification and More Time to Address
Paragraphs 2, 3, and 5 of the…
giuffre-maxwell
gov.uscourts.nysd.447706.684.0
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.733.0
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…[email protected]
/s/ Meredith Schultz
Meredith Schultz, Esq.
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endor…
giuffre-maxwell
gov.uscourts.nysd.447706.996.0
14 pg
…So they present more or less similar arguments. We request leave to address their three
separate briefs in a single reply brief. We submit this will be more succinct and efficient and less
repetitious for the Court.
As the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.29
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.447706.1020.0
7 pg
…project. Before reaching the merits of
sealing/redaction of the Sealed Materials we think it appropriate and necessary to
address the complexity and difficulty of the project as well as its difficult-to-overstate
importance to the lives of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…And, once again, the Court ordered
Defendant to answer questions about the subjects she had refused to address, enumerating four
specific topics:
The Plaintiff has moved to compel answers to questions which were the subject of
the June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1250.0
7 pg
…attempt to comply with New York
Civil Rights Law (“CRL”) § 50-b(1). Moreover, the government did not address the
constitutional access issues implicated in the instant case. See id. (“Other than relying on CRL §
Case 1:15-cv…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.12_1
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.447706.1256.23
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.447706.1331.14
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.447706.1330.12
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.447706.1332.12
7 pg
…the Court may appoint a special master to “address pretrial
and post-trial matters that cannot be effectively and timely addressed by an available district
judge or magistrate judge of the district.” In light of the trial in this matter…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
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.447706.651.0
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
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.447706.1331.5
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.514.0
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.
…
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