giuffre-maxwell
gov.uscourts.nysd.447706.27.0
3 pg
…Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S MOTION FOR LEAVE TO BRING PERSONAL ELECTRONIC
DEVICES AND GENERAL PURPOSE COMPUTING DEVICES INTO THE
COURTHOUSE FOR THE JANUA…
giuffre-maxwell
gov.uscourts.nysd.447706.27.1
3 pg
…Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
[PROPOSED] ORDER ON PLAINTIFF’S MOTION FOR LEAVE TO BRING
PERSONAL ELECTRONIC DEVICES AND GENERAL PURPOSE COMPUTING
DEVICES INTO THE COURTHOUSE FOR JANU…
giuffre-maxwell
gov.uscourts.nysd.447706.91.0
3 pg
…she further avers as follows:
Defendant was forced to bring her Motion to Compel as to each and every one of
Plaintiff’s interrogatory responses and each and every one of her responses to the Request for
Production.
The issues…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.28
3 pg
…s pedophile proclivities.
One source told the cops, according to
Radar's report, that Epstein had promised,
"I'll pay you if you bring some girls. He told
her the younger the better. [The girl] once
stated she once tried…
giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…not
granted Mr. Cernovich intervention under Rule 24(b).
Accordingly, he is not a party of this litigation, and has no standing to bring the instant
opposition. See Esther Sadowsky Testamentary Trust v. Federal Housing Finance Agency, 412
Fed.Appx…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…been in a suit criminal or civil and want it to stay that way.
The US lawyers for the Jane Does are filling additional discovery motions and if I speak I open my self to being
part of discovery apparently…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…Complaints may be made direct to the barrister /
their Chambers. Please note that there may be a time limit for bringing your complaint. You may also have the right to ask the Legal Ombudsman to consider your complaint
at the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.16
2 pg
…case is awaiting an argument date in the Second Circuit Court of Appeals.
Against that backdrop, Intervenor seeks to bring to this Court’s attention his June 21,
2017 letter to Your Honor (ECF No. 922) (the “June 2017 Letter”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…Complaints may be made direct to the barrister /
their Chambers. Please note that there may be a time limit for bringing your complaint. You may also have the right to ask the Legal Ombudsman to consider your complaint
at the…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…10022; 954-356-00'1 '1
: 06/1'1/2016 at 9:00 a.m.
----'--
You, or YOllr representatives, must also bring
giuffre-maxwell
gov.uscourts.nysd.447706.1049.0
91 pg
…Discovery
22 12.15.15 28 1.20.16
Pending Decision on
Defendant's Motion to Dismiss
Plaintiff's Motion for Leave to
Bring Personal Electronic Device
27 1.8.16 51 3.14.16
…
giuffre-maxwell
gov.uscourts.nysd.447706.440.1
21 pg
…16,
16, 2016.
2016. The
commands Churcher to
Subpoena also commands to bring with her to the
documents:
deposition several broad categories of documents:
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.2
4 pg
…me, the fitting room, which was very odd.
18 Q. Did he make any comments about being in
19 the fitting room with you?
20 A. He joked that one time he was in there
21 with another girl, and…
giuffre-maxwell
gov.uscourts.nysd.447706.961.0
9 pg
…who are taking the view
that the time for implementing the destruction provisions has yet to arrive. While Ms. Maxwell
brings this motion asking for immediate relief, this matter has been under discussion for more
than one year. And Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1111.1
55 pg
…in support thereof,
would show unto the Court as follows:
JURISDICTION AND PARTIES
1. The Attorney General of the United States Virgin Islands (herein after "Virgin
Islands") brings this action on behalf of the Plaintiff, Government of the Virgin Islands…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…Kellen be directed to appear for her deposition; (2) that Ms.
Kellen pay Ms. Giuffre’s costs and reasonable attorney’s fees associated with bringing this
motion; (3) that Ms. Kellen be ordered to pay a civil penalty of $2500…
giuffre-maxwell
gov.uscourts.nysd.447706.59.0
5 pg
…Any
communications with counsel for the purpose of seeking/receiving legal advice related to bringing a
Case 1:15-cv-07433-LAP Document 59 Filed 03/15/16 Page 2 of 5
claim are privileged under the attorney-client…
giuffre-maxwell
gov.uscourts.nysd.447706.378.0
50 pg
…10
2. This Court Has Already Ruled Against Defendant on Pre-1999
Medical Records, so Defendant is Estopped From Bringing This
Argument..................................................................................................15
…
giuffre-maxwell
gov.uscourts.nysd.447706.211.0
16 pg
…in
advance as possible – thereby permitting counsel for both side to schedule the remaining
depositions – Ms. Giuffre brings the motion now. She also requires a ruling in advance so that
she can make final plans about how many depositions she…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…trial-preparation material, the person malcing the claim may notify any party
significant expense resulting from compliance. that received the infonnation of the claim and the basis for it. After being
notified, a party…
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