giuffre-maxwell
gov.uscourts.nysd.447706.1090.4_1
29 pg
…TABLE OF AUTHORITIES ....................................................................................................... ii
CERTIFICATE OF CONFERRAL ............................................................................................ 1
INTRODUCTION.......................................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…TABLE OF AUTHORITIES ....................................................................................................... ii
CERTIFICATE OF CONFERRAL ............................................................................................ 1
INTRODUCTION.......................................................................................…
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.447706.234.0
4 pg
…Defendant’s Motion to
Quash Subpoena to Jeffrey Epstein.
3. Attached hereto as Exhibit 1, is a true and correct copy of Sigrid McCawley’s
March 7, 2016 Correspondence to Martin G. Weinberg, Esquire.
4. Attached hereto as Exhibit 2…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…conducted were thorough enough then ensued leading to the instant
submission.
2
searched yet there is no RFP related to those names, nor the vast majority of the other listed first
and surnames.1
By correspondence of July 14, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.25
4 pg
…UT 84112
(801) 585-52022
2
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.447706.66.0_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.447706.1202.3_1
4 pg
…Reply to Plaintiff’s Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition.
2. Attached as Exhibit A (filed under seal) is a true and correct copy of
correspondence from Meredith Schultz to me dated June 30, 2016.
3…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.22
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.447706.1202.1_1
11 pg
…LAP Document 1202-1 Filed 01/27/21 Page 5 of 11
searched yet there is no RFP related to those names, nor the vast majority of the other listed first
and surnames.1
By correspondence of July 14, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.23
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.447706.1218.39
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.447706.71.6
19 pg
…papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence,
telegrams, drafts, data processing or computer diskettes and CD disks, tapes of any nature and
computer interpretations thereof, instructions, announcements, and sound recordings of any
nature. “Document” also means all copies which…
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.447706.1256.6
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.447706.422.0
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.447706.229.6
24 pg
…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.
Case 1:15-cv-07433…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.39
5 pg
…and Motion for Sanctions for Violation of
Rule 45.
3. Attached hereto as Exhibit 1, is a true and correct copy of Sigrid McCawley’s
March 7, 2016 Correspondence to Martin G. Weinberg, Esquire.
4. Attached hereto as Exhibit 2…
giuffre-maxwell
1320-22.2
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
1320-25
4 pg
…UT 84112
(801) 585-52022
2
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.
…
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