giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…decision
by the Court to undercut that purpose. Should Does 1 and 2 wish
to submit a more thorough explanation for their objection, doing
so would be to the benefit of all involved in this process.
Third, and relatedly, that …
giuffre-maxwell
gov.uscourts.nysd.447706.1006.0
1 pg
…Therefore, the Court
can have the benefit of whichever format it prefers to work from. Plaintiff’s format includes the
specifics of sealed orders and details of the sealed exhibits for ease of the Court’s reference and
accordingly is…
giuffre-maxwell
gov.uscourts.nysd.447706.441.0
18 pg
…in resolvingthe issu es,and whetherthe bu rd en orex pense of the proposed
d iscovery ou tweighs its likely benefit.
Ru le 26(b)(1),Fed .R.C iv.P .D efend ant’s d iscovery requ ests foremploymentand…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…of 12
has shut. Expert reports have been exchanged, so Ms. Giuffre’s experts did not have the benefit
of reviewing these documents. Late production of this information robs Ms. Giuffre of any
practical ability to use the discovery, and…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…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 discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…would be both untimely and prejudicial. Fact discovery has closed.
Numerous depositions have already been taken by Ms. Giuffre without the benefit of these
documents. The window for authenticating the documents through depositions has shut. Expert
reports are due at…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…untimely and prejudicial. Fact
discovery has closed. Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
has shut. Expert reports have been exchanged, so Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…would be both untimely and prejudicial. Fact discovery has closed.
Numerous depositions have already been taken by Ms. Giuffre without the benefit of these
documents. The window for authenticating the documents through depositions has shut. Expert
reports are due at…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…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 discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…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 discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…denying Ms. Giuffre the benefit of being able to use these e-
mails at multiple witness depositions. The only “untimeliness” claim that can be made here is against
1111
the Defendant.
-
The two emails in question are responsive to a…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…– i.e. the alleged benefit she was promised.
The few documents produced suggest that the denial of admission to F.I.T. (if that is what
occurred) is more likely a result of lack of required credentials or her failure…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…19
10. “Income” includes, without limitation, any revenue, payments, compensation,
remuneration, financial benefit or support or any other financial consideration, or provision of
any other thing of value.
11. “Person” means any natural person, individual, firm, partnership, association,
joint venture…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…would be both untimely and prejudicial. Fact discovery has closed.
Numerous depositions have already been taken by Ms. Giuffre without the benefit of these
documents. The window for authenticating the documents through depositions has shut. Expert
reports are due at…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…would be unnecessarily cumulative, whether the
party requesting the deposition has had other opportunities to obtain the same information, and
whether the burden of a second deposition outweighs its potential benefit.’” Official Comm. of
Unsecured Creditors of Exeter Holdings, Ltd.…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…foreign or domestic, directly or
indirectly held by You, or held on Your behalf or for Your benefit by another individual or
entity, including trusts from January 2015 to the Present.
DOCUMENT REQUEST NO. 34
Produce all accounts receivable ledgers…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…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 discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
1320-37
48 pg
…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 discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…untimely and prejudicial. Fact
discovery has closed. Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
has shut. Expert reports have been exchanged, so Ms…
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