giuffre-maxwell
gov.uscourts.nysd.447706.1219.8
29 pg
…The objections and responses to the RFPs are proper. ................................................ 1
A. RFP No. 1: Documents defense counsel “reviewed and/or relied upon” in a phone
call with Plaintiff’s counsel. ...................................................................................... 1
B. RFP N…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.1_1
13 pg
…01/27/21 Page 2 of 13
information contained therein.
I. BACKGROUND
In a March 21, 2016, meet-and-confer call, Defendant’s counsel specifically referenced
certain police reports wherein Ms. Giuffre was identified as a victim. On April 14…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 276 Filed 07/13/16 Page 2 of 35 2
G6ndgium
1 (Case called)
2 THE COURT: Extending discovery.
3 MS. McCAWLEY: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…She was unable to crawl . .
.Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport
her to [REDACTED] to check on her condition. I then met with [REDACTED] and his
mother. I advised [REDACTED] of his Miranda rights…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.31
13 pg
…very next page, when discussing the information gleaned
from those police reports that Mr. Pagliuca had prior to the conferral call, Defendant claims the
information from the police reports is “irrelevant,” stating: “The records requested are
irrelevant. Plaintiff has asserted…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 849 Filed 04/12/17 Page 2 of 94 2
H3u1giua
1
2 (Case called)
3 THE COURT: We have a problem, folks…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 847 Filed 04/12/17 Page 2 of 94 2
H3u1giua
1
2 (Case called)
3 THE COURT: We have a problem, folks…
giuffre-maxwell
gov.uscourts.nysd.447706.983.0
24 pg
…7 MS. McCAWLEY: The parties have conferred. We had a
8 long conference call to discuss the various issues that are at
9 hand here. As the Court well knows, the Second Circuit has
10 returned this case to you…
giuffre-maxwell
gov.uscourts.nysd.447706.1196.0
32 pg
…KRIEGER
23
24
25
SOUTHERN DISTRICT REPORTERS, P.C.••
(212) 805-0300
L1JMGIUC
Case 1:15-cv-07433-LAP Document 1196 Filed 01/27/21 Page 2 of 32 2
1 (Case called)
2 THE COURT: Good morning, counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 1021 Filed 01/23/20 Page 2 of 18 2
K1G5giuC conference
1 (Case called)
2 THE COURT: Is plaintiff's counsel ready?
3…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.16_1
12 pg
…She was unable to crawl . .
.Based on [REDACTED] intoxicated condition, a [sic] ambulance was called to transport
her to [REDACTED] to check on her condition. I then met with [REDACTED] and his
mother. I advised [REDACTED] of his Miranda rights…
giuffre-maxwell
gov.uscourts.nysd.447706.1215.0
13 pg
…jury pool that will hear Ms.
Giuffre’s case. The Court should not allow such callous abuse of a First Amendment right,
particularly as there is no merit to Dershowitz’s claim (Br. at 21) that ‘public monitoring has an
…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…issue here . . . call[ed] upon
the court to exercise its Article III powers” and “are subject to at least some presumption of public
access.” Brown, 929 F.3d at 50. “[A]ll documents submitted in connection with, and relevant to…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…from Law Enforcement Agencies in
Florida and Colorado ....................................................................................................... 4
B. No State Statute Forbids Disclosure of the Documents ....................................................... 6
C. All Documents Were Reda…
giuffre-maxwell
gov.uscourts.nysd.447706.1050.0
12 pg
…your Honor.
12 THE COURT: Good. Our thought was also following this
13 call, we should docket the final protocol and the forms that we
14 have come up with so that it's out there for everyone to see…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…gossip arising from a compelled deposition.
2
The parties attempted to call the court for a ruling during the deposition but were
advised by chambers to “bring any issue to him after the conclusion of the deposition.” See 316-
6…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…her criminal
proceedings,3 and will only to lead to more disputes. Even deciding what groups should exist and
what to call them will likely lead to disagreement, and the process of deciding which Non-Party
fits into which group…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…case. This is the
so-called “mandate rule.” The second and more flexible branch is implicated when
a court reconsiders its own ruling on an issue in the absence of an intervening ruling
on the issue by a higher court…
giuffre-maxwell
gov.uscourts.nysd.447706.63.0
22 pg
…listed discovery issues can be properly resolved in
advance of that time.
Certificate of Conferral
Counsel has conferred numerous times regarding the issues contained herein, most
recently in a one hour and 45 minute phone call on March 21, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…ask her what she told the FBI and thus clear up any confusion about the redactions. Indeed,
Defendant also remains free to call the FBI Agents who were involved in the interview or the
Assistant U.S. Attorney who listened…