giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…had hired ex-L.A. police detective Mark Fuhrman as a consultant that his title
was changed, GMA chief Shelley Ross confirmed Wednesday.
Fuhrman, who pled out to perjury charges after denying at O.J. Simpson’s 1996 murder trial…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…filing will be delayed if Andrew accepts the interview request by January 19.
The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to accept the letter to Prince
Andrew and that it was returned to…
giuffre-maxwell
gov.uscourts.nysd.447706.1300.0
4 pg
…Party pseudonyms of the Non-Parties to whom
Plaintiff sent the Non-Party Notices. Plaintiff has confirmed that this error has not had any other
impact on the unsealing process thus far.
6. Pursuant to this Court’s August 26…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The recent forensic imaging and searches have merely
confirmed as much. Plaintiff has sent defense counsel, this Court and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…The parties have confirmed that Plaintiff’s deposition has yet to be taken
in light of this outstanding discovery dispute.
Having reviewed and considered Defendant’s motion to compel [DE 40] and Plaintiff’s
opposition [DE 41] the Court is…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…identified. Ms. Maxwell’s original search for responsive documents was complete at the time it
was conducted in February 2016. The recent forensic imaging and searches have merely
confirmed as much. Plaintiff has sent defense counsel, this Court and Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…requested by
Plaintiff, and all responsive documents produced. This expensive, costly and time consuming
exercise in futility simply confirmed that all responsive documents, including all responsive
emails, were produced in March and April 2016.
Most significantly, the devices were searched…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…did not correct this testimony.
In her Reply Brief, Ms. Churcher has confirmed that Professor Dershowitz
was not among the prominent individuals that Ms. Giuffre was accusing of
sexual misconduct. The Reply Brief affirmatively argues that Ms.
Churcher was…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…requested by
Plaintiff, and all responsive documents produced. This expensive, costly and time consuming
exercise in futility simply confirmed that all responsive documents, including all responsive
emails, were produced in March and April 2016.
Most significantly, the devices were searched…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…with his client. I then made telephone contact with the
State Attorneys Office and confirmed that subpoenas would be issued
to the former employees to assist in the investigation.
I then made telephone contact with Attorney Guy Fronstin, attorney for…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…with his client. I then made telephone contact with the
State Attorneys Office and confirmed that subpoenas would be issued
to the former employees to assist in the investigation.
I then made telephone contact with Attorney Guy Fronstin, attorney for…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Party Witness to Produce Documents and Respond to Deposition Questions, and Response
to Motion for Protective Order for Non-Party Witness (ECF 640)1 and further states as follows:
STATEMENT OF CONFERRAL
The undersigned has conferred with Mr. Stanley Pottinger…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…AMD, 2010 WL 2483294, at *3 (D.N.J. June 4, 2010).
That pre-trial discovery on financial matters is allowed when a punitive damage issue is
present in a case is confirmed by Tillery v. Lynn, 607 F. Supp…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…AMD, 2010 WL 2483294, at *3 (D.N.J. June 4, 2010).
That pre-trial discovery on financial matters is allowed when a punitive damage issue is
present in a case is confirmed by Tillery v. Lynn, 607 F. Supp…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…by her own choosing. Deposition by videoconference
will be extremely cumbersome to accomplish given the hundreds of pages of documents to be
1
Defendant conferred with counsel for Plaintiff regarding this Motion prior to its filing. By email of May…
giuffre-maxwell
gov.uscourts.nysd.447706.229.6
24 pg
…I was hoping you could tell me whether she is
represented and whether next week works for her or will also need resetting.
As of right now, the only confirmed depo for next week is that of Mr. Rizzo.
Laura…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…Lauderdale, FL Oxford, FL
(confirmed) (confirmed)
22 23 24 25 26 27 28
Deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…s rendezvous with
Virginia Roberts in Ghislaine Maxwell’s London home, they carried strong disclaimers saying there was no
suggestion of any sexual contact between Prince Andrew and Roberts.”).
6
This is confirmed by the articles themselves. See Churcher Decl…
giuffre-maxwell
1320-13
45 pg
…with his client. I then made telephone contact with the
State Attorneys Office and confirmed that subpoenas would be issued
to the former employees to assist in the investigation.
I then made telephone contact with Attorney Guy Fronstin, attorney for…
giuffre-maxwell
gov.uscourts.nysd.447706.535.0
18 pg
…McCawley Decl. at Exhibit 2, Gregory B. Taylor Dec. 2, 2016, Dep. Tr. pp. 22-23.
Further deposition questions confirmed that
4
5
See McCawley Decl. at Exhibit 2, Gregory B. Taylor Dec. 2, 2016, Dep. Tr. pp. 132…
Comments