giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…to Plaintiff’s Second Request for Production of Documents (the “Requests”).
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
1. This response is made to the best of Ms. Maxwell’s present knowledge,
information and belief. Ms. Maxwell, through her attorneys of record…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…All Documents containing Communications with Virginia Roberts Giuffre, or any of her
attorneys, agents, investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…All Documents containing Communications with Virginia Roberts Giuffre, or any of her
attorneys, agents, investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…All Documents containing Communications with Virginia Roberts Giuffre, or any of her
attorneys, agents, investigators, from the period 1999-present.
RESPONSE:
In addition to the Preliminary Statement and General Objections, Ransome objects to this
request in that she is a…
giuffre-maxwell
1320-17
25 pg
…to Plaintiff’s Second Request for Production of Documents (the “Requests”).
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
1. This response is made to the best of Ms. Maxwell’s present knowledge,
information and belief. Ms. Maxwell, through her attorneys of record…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…to Plaintiff’s Second Request for Production of Documents (the “Requests”).
PRELIMINARY STATEMENT AND GENERAL OBJECTIONS
1. This response is made to the best of Ms. Maxwell’s present knowledge,
information and belief. Ms. Maxwell, through her attorneys of record…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
… “Agent” shall mean any agent, employee, officer, director, attorney, independent
contractor or any other person acting, or purporting to act, at the discretion of or on behalf of
another.
2. “Correspondence” or “communication” shall mean all written or verbal
communications…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…any disputes expeditiously. These courts have generally permitted
redactions and sealing to protect the names and personally identifiable information of victims,
which is what Plaintiff seeks here.
Much has changed since 2019 and the initial unsealing protocol. The Defendant in…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…ROBERT W. SWEET,
12
12 District Judge
13
13 APPEARANCES
14
14 STANLEY POTTINGER PLLC
15 Attorneys for Plaintiff
15 BY: STANLEY POTTINGER
16
16 S.J. QUINNEY COLLEGE OF LAW AT THE UNIVERSITY OF UTAH
17 Attorneys for Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…N. Walz
31 West 52nd Street
New York, NY 10019
Telephone: 212.513.3200
Fax: 212.385.9010
Attorneys for Intervenors
Julie Brown and Miami Herald Media Company
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
:
VIRGINIA L. GIUFFRE…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…information at trial where it relates only to a claim for punitive damages. The Court noted:
In view of every citizen’s right to privacy and the general desire of people not to
divulge their wealth, on the one hand…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…information at trial where it relates only to a claim for punitive damages. The Court noted:
In view of every citizen’s right to privacy and the general desire of people not to
divulge their wealth, on the one hand…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…persons, Epstein
and Kellen, have attorneys who have not been authorized by their clients to accept service). Ms.
Giuffre seeks leave to provide service by several alternative means that are designed to assure
actual notice is provided to these persons…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…persons, Epstein
and Kellen, have attorneys who have not been authorized by their clients to accept service). Ms.
Giuffre seeks leave to provide service by several alternative means that are designed to assure
actual notice is provided to these persons…
giuffre-maxwell
1320-8
12 pg
…persons, Epstein
and Kellen, have attorneys who have not been authorized by their clients to accept service). Ms.
Giuffre seeks leave to provide service by several alternative means that are designed to assure
actual notice is provided to these persons…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…of the United States in September 1974, 1s required for use of the Clerk of Court for the purpose of
initiating the civil docket sheet.
PLAINTIFFS DEFENDANTS
Virginia L. Giuffre …
giuffre-maxwell
gov.uscourts.nysd.447706.1035.0
2 pg
…submitted,
HOLLAND & KNIGHT LLP
/s/ Christine N. Walz
Sanford L. Bohrer
Christine N. Walz
31 West 52nd Street
…
giuffre-maxwell
gov.uscourts.nysd.447706.1036.0
2 pg
…West 52nd Street
New York, NY 10019
The parties shall confer and Telephone: 212.513.3200
submit a proposed redacted Fax: 212.385.9010
list of decided motions to
be filed on the public Attorneys for Intervenors
docket. SO ORDERED…
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