giuffre-maxwell
gov.uscourts.nysd.447706.1154.0_5
3 pg
…various
issues surrounding the unsealing protocol.
In the final paragraph of her November 10, 2020 correspondence, Plaintiff asserts her
belief that the Court will consider in this current round of unsealing not only whether to
release Doe 1 and 2…
giuffre-maxwell
gov.uscourts.nysd.447706.338.1
4 pg
…Instruction Based on New Information.
3. Attached hereto as Exhibit 1 is a true and correct copy of July 29, 2016,
Correspondence from Ty Gee.
4. Attached hereto as Sealed Exhibit 2
5. Attached hereto as Sealed Exhibit 3 i
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.31
2 pg
…Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition.
2. Attached as Exhibit D (filed under seal) is a true and correct copy of
correspondence between Plaintiff and literary agent Marianne Strong dated February 19, 2014
and February 21…
giuffre-maxwell
gov.uscourts.nysd.447706.813.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is not intended
to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.29
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1020.0
7 pg
…and the non-parties.
The volume of Sealed Materials is substantial. The Sealed Materials contain motions,
responses, replies, surreplies, sur-surreplies, memoranda, correspondence, declarations,
exhibits, notices, and orders. Depending whether the materials were filed under seal,
each motion, response, etc.…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
3 pg
…3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of May 18, 2016,
Correspondence from Jeff Pagliuca to Meredith Schultz.
4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of May 20…
giuffre-maxwell
gov.uscourts.nysd.447706.66.0_1
35 pg
…say this. If you have a meet and confer,
24 I would like to have correspondence between the parties as to
25 what the subject is so that there is an agreed agenda that's
SOUTHERN DISTRICT REPORTERS, P.C…
giuffre-maxwell
gov.uscourts.nysd.447706.573.0
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.514.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.20
4 pg
…is a true and correct copy of January 2, 2015,
E-mail Correspondence (RG(UK)_00009).
Case 1:15-cv-07433-LAP Document 1331-20 Filed 01/05/24 Page 2 of 4
7. Attached hereto as Sealed Exhibit…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.39
36 pg
…say this. If you have a meet and confer,
24 I would like to have correspondence between the parties as to
25 what the subject is so that there is an agreed agenda that's
SOUTHERN DISTRICT REPORTERS, P.C…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…Defendant with twenty (20) days from the date of the Court’s hearing compelling production.
See Declaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, March 28, 2016
Correspondence. Defendant failed to respond and failed to produce anything, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.955.0
43 pg
…Esq.
1 This daytime business address is provided for
identification and correspondence purposes only and is not
intended to imply institutional endorsement by the University of
Utah for this private representation.
Case 1:15-cv-07433-RWS
Case 1…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…Laura Menninger’s February 25, 2016 Email Correspondence to Sigrid McCawley.
Case 1:15-cv-07433-LAP
Case Document
1:15-cv-07433-RWS 1206-4
Document Filed03/04/16
41 Filed 02/04/21 Page
…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.9
4 pg
…com
/s/ J. Stanley Pottinger
J. Stanley Pottinger, Esq.
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by …
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…the document forthwith and sanction
Plaintiff for her conduct.
STATEMENT OF CONFERRAL
The undersigned has conferred extensively with Plaintiff’s counsel on this issue by
telephone and email, as demonstrated in the correspondence attached hereto in Menninger Decl.
Ex. B…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.2
4 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only and is
not intended to imply institutional endorsement by the University of Utah for this private representation.
…
giuffre-maxwell
gov.uscourts.nysd.447706.858.0
3 pg
…UT 84112
(801) 585-52021
1
This daytime business address is provided for identification and correspondence purposes only
and is not intended to imply institutional endorsement by the University of Utah for this private
representation.
2…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.25_2
3 pg
…3
13. Attached as Exhibit L (filed under seal) is the certificate of service for
14. Attached as Exhibit M is a true and correct copy of my correspondence to
Plaintiff’s counsel of May 25, 2016.
15. Attached as…
Comments