giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
B…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
B…
giuffre-maxwell
1320-18
40 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
RESPONSE TO MOTION TO COMPEL ATTORNEY-CLIENT COMMUNICATIONS
AND ATTORNEY WORK PRODUCT MATERIALS
B…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…HON. LORETTA A. PRESKA,
12
District Judge
13
APPEARANCES
14
BOIES SCHILLER & FLEXNER
15 Attorneys for Plaintiff Giuffre
BY: SIGRID S. McCAWLEY
16 ANDREW VILLACASTIN
SABINA MARIELLA
17
HADDON MORGAN & FOREMAN PC
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.6
10 pg
…of Palm Beach Police Department and the State
Attomoy's Offlce for the lSth Judicial Circuit in and for Palm Beach Cowity (hereinafter,
the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey
Epstein (hereinafter "Epstein")…
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1150.0
56 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1209.0
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.672.0
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…of my knowledge
as follows:
BACKGROUND
1. I am a licensed attorney in the state of Utah. I am authorized to practice before
this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…of my knowledge
as follows:
BACKGROUND
1. I am a licensed attorney in the state of Utah. I am authorized to practice before
this Court pursuant to this Court’s Order granting my Application to Appear Pro Hac Vice.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.789.0
3 pg
…follows:
1. I am an attorney at law duly licensed in the State of New York and admitted to
practice in the United States District Court for the Southern District of New York. I am a
member of the law…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…LORETTA A. PRESKA,
11
District Judge
12
13
APPEARANCES
14
BOIES, SCHILLER & FLEXNER, LLP
15 Attorneys for Plaintiff
BY: SIGRID S. McCAWLEY
16
17 HADDON MORGAN & FOREMAN, P.C.
Attorneys for Defendant
18 BY…
giuffre-maxwell
gov.uscourts.nysd.447706.592.0
5 pg
…DEFENDANT’S COUNTER-DESIGNATIONS TO PLAINTIFF’S
DEPOSITION DESIGNATIONS
Defendant Ghislaine Maxwell, through her attorneys and pursuant to Rule 32 of the
Federal Rules of Civil Procedures, hereby submits her counter-designations in accordance with
the Court’s October 3…
giuffre-maxwell
gov.uscourts.nysd.447706.671.0
4 pg
…AND FOREMAN, P.C.
150 East 10th Avenue
Denver, CO 80203
Phone: 303.831.7364
Fax: 303.832.2628
[email protected]
Attorneys for Ghislaine Maxwell
7
…
giuffre-maxwell
gov.uscourts.nysd.447706.1353.0
6 pg
…Accordingly,
Judge McMahon modified the protective order:
Upon the Affirmation and Application of the United States Attorney
for the Southern District of New York … requesting that an Order
be issued relieving Boies Schiller & Flexner of their obligations un-
der…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…C: Counsel of Record (via ECF); Kerrie Campbell (via Email)
1
Attorney Kerrie Campbell represents one of the third parties whose
identifying information appears in some of the sealed materials and who moved
to intervene in the consolidated appeals. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…2d 325, 326 (N.Y.A.D.,1994) (affirming the denial of a
request for records held by the New York County District Attorney’s office).2
1
Portions of this brief are redacted because they quote from, or describe…
giuffre-maxwell
gov.uscourts.nysd.447706.962.0
7 pg
…by
the parties, none of which is at issue in the appeals.
Ms. Giuffre and her attorneys argue this Court lacks jurisdiction because three appeals
are pending challenging this Court’s denial of unseal motions. They cite Griggs v. Provident
…
giuffre-maxwell
gov.uscourts.nysd.447706.1.0
12 pg
…with the victims about the NPA, the U.S. Attorney’s Office
and Epstein agreed to a “confidentiality” provision in the Agreement barring its disclosure to
anyone—including Epstein’s victims. As a consequence, the victims were not told about…
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