…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL …
…November 12, 2015. And call me if you have any questions. Regards, Barry Meier -- The New York Times 620 Eighth Avenue New York, NY 10018 212-556-1917 1 CONFIDENTIAL GM_01141 Case 1:15-cv-07433-LAP Document 1219…
…November 12, 2015. And call me if you have any questions. Regards, Barry Meier -- The New York Times 620 Eighth Avenue New York, NY 10018 Jane Doe 2 1 CONFIDENTIAL GM_01141 Case 1:15…
…November 12, 2015. And call me if you have any questions. Regards, Barry Meier -- The New York Times 620 Eighth Avenue New York, NY 10018 212-556-1917 Jane Doe 2 1 CONFIDENTIAL GM_01141 …
…November 12, 2015. And call me if you have any questions. Regards, Barry Meier -- The New York Times 620 Eighth Avenue New York, NY 10018 212-556-1917 1 CONFIDENTIAL GM_01141 Case 1:15-cv-07433-LAP Document 1219…
…in for that conference is (888) 363-4734, access code: 4645450. The parties are directed to call in promptly at 2:00 p.m. SO ORDERED. Dated: New York, New York June 19, 2020 1 With respect to Giuffre v…
…6 A. Controlling Second Circuit Case Law from LiButti v. United States Permits Calling a Witness for Purposes of Obtaining Adverse Inferences.......................... 7 B. Federal Law Rather than New York Law Controls the Evidentiary Issue of Whether …
…15-cv-07433-LAP Document 587 Filed 02/02/17 Page 2 of 10 2 H1j6giua 1 (In open court; case called) 2 THE COURT: Please be seated. 3 I will hear from the movant. 4 MR. PAGLIUCA: Good afternoon…
…Ghislaine Maxwell Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre v. Maxwell, Case No. 15-cv- 07433-RWS…
…Response: Maxwell objects to this Request on the grounds that it is overly broad and unduly burdensome and calls for the production of documents that are irrelevant to this action and not reasonably calculated to lead to the discovery of…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REPLY IN SUPPORT OF MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL …
…aware, Ms. Giuffre has alleged that Defendant defamed her when she called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of Defendant and Defendant’s long-time boyfriend, convicted…
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY IN SUPPORT OF MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL I…
…of privileged and potentially privileged documents. For example, Defendant’s Request No. 20 calls for the production of “[a]ny Document reflecting Your intent, plan or consideration of, asserting or threatening a claim or filing a lawsuit against another Person…
…because they did not “lead to an inference that Plaintiff is a ‘liar and an extortionist.’” In vivid contrast, Maxwell called Ms. Giuffre’s assertions of sexual abuse “obvious lies.” It is axiomatic that a person telling “obvious lies” is…
… Regardless, Philip plse call jeffrey lawyer and see what you can under.stand from him and pehaps craft something in conjunction with him? Either way I think you need to speak to him to understand my risk so you can…
…first and surnames.1 By correspondence of July 14, Ms. Maxwell’s counsel specifically identified the problematic terms, agreed to a limited list, and requested a substantive conferral call on this issue. See Menninger Decl., Ex. B. In that correspondence…
…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…
…the definition of judicial documents as articulated in Brown. When filed, motions “call upon the court to exercise its Article III powers” because they call for and intend to influence judicial decision-making. See Brown, 929 F.3d at 50. “…
… Regardless, Philip plse call jeffrey lawyer and see what you can under.stand from him and pehaps craft something in conjunction with him? Either way I think you need to speak to him to understand my risk so you can…
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