giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…particular documents are being withheld, let alone other relevant information about the
withheld documents (e.g., date, author, subject matter). Because Dershowitz is not in a position
to tailor his arguments to specific assertions of privilege, Dershowitz addresses the asserted…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…f. the disposition of any case associated with any such Communication, irrespective
of whether the matter was sealed, expunged or later dismissed.
5. Identify each Communication that You or Your Attorneys have had with any
author, reporter, correspondent, columnist, writer…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.5
45 pg
…to any party’s claim or defense; and documents that are not proportional to the
needs of the case. Such requests would create a heavy burden on Ms. Giuffre that outweighs any
benefit. Such discovery is prohibited by the Federal…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…award
Ms. Maxwell reasonable attorney fees and costs incurred in bringing this Motion.
I. Plaintiff’s interrogatory responses are deficient.
Interrogatory No. 5. Identify each Communication that You or Your Attorneys
have had with any author, reporter, correspondent, columnist, writer…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
1320-37
48 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…the issues; documents that are not relevant to
any party’s claim or defense; and documents that are not proportional to the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…it is well-recognized that the non-moving party faced with a summary judgment
motion supported by appropriate proof may not rely on bare, conclusory assertions found in the
pleadings to create an issue and thus avoid summary judgment. Instead…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…is a gentleman
17 by the name of Stan Pottinger. He is a lawyer of some renown.
18 He is also an author of best-selling books. He is listed quite
19 frequently on plaintiff's privilege log as being…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…history on a number of
occasions, including during her interviews with ABC, with other media outlets, with book
authors and journalists, but chose not to tell her true story, instead telling falsehoods and
fabricated and mistaken events, dates and participants.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.24
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
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Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
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giuffre-maxwell
gov.uscourts.nysd.447706.1218.30
4 pg
…prostitute Filed
| News 07/15/21 Page 2 of 4Page 1 of 3
- Home
Alan Dershowitz: 'Sex slave' accuser is serial liar, prostitute
Famed attorney slams woman who claims he had underaged sex with her
A…