giuffre-maxwell
gov.uscourts.nysd.447706.233.0
9 pg
…date, Epstein’s motion to quash is untimely, the Court should deny
it for that reason alone.
6
CONCLUSION
Epstein’s motion to quash should be denied and Ms. Giuffre should be entitled to take
Epstein’s deposition.
Dated…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.5
4 pg
…commencing July 22,
2016, 9:04 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New York, New York 10026
…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.15_1
4 pg
…commencing July 22,
2016, 9:04 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New York, New York 10026
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.21_2
4 pg
…commencing
April 22, 2016, 9:04 a.m., on the above
date, before Leslie Fagin, a Court
Reporter and Notary Public in the State
of New York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New York, New York 10026…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Dershowitz on that same
date and time.
5. Any documents and information that support and/or confirm your presence at the various
locations named in Paragraphs 24-31 of your Declaration on the particular dates and
times when Alan M…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.32
4 pg
…details of his person and the sex
acts and can describe th.em in the event it becomes necessary to do so.
I affirm under penalty of perjury that the foregoing is true and correct.
Dated: (JS - 0 l - .' 20 …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…this Response in Opposition to
Plaintiff’s Motion to Exceed Presumptive Ten Deposition Limit, and states as follows:
INTRODUCTION
Despite having taken only three depositions to date, Plaintiff prematurely requests
permission to exceed the presumptive ten deposition limit imposed by…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.10
14 pg
…commencing June 10,
2016, 10:06 a.m., on the above date,
before Leslie Fagin, a Court Reporter
and Notary Public in the State of New
York.
- - -
MAGNA LEGAL SERVICES
1200 Avenue of the Americas
New Y…
giuffre-maxwell
gov.uscourts.nysd.447706.229.6
24 pg
…Depositions next week
Date: Thursday, June 02, 2016 9:23:30 AM
We got an email yesterday from Mr. Brunel's attorney saying he needs to reschedule. I believe he is trying to get us
new dates today or tomorrow…
giuffre-maxwell
gov.uscourts.nysd.447706.215.0
2 pg
…the first Thursday following the
completion of briefing) or a later date convenient for the Court.
DWT 29803975v1 0085000-002358
Case 1:15-cv-07433-LAP Document 215 Filed 06/15/16 Page 2 of 2
Dated: New York…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…this Response in Opposition to
Plaintiff’s Motion to Exceed Presumptive Ten Deposition Limit, and states as follows:
INTRODUCTION
Despite having taken only three depositions to date, Plaintiff prematurely requests
permission to exceed the presumptive ten deposition limit imposed by…
giuffre-maxwell
gov.uscourts.nysd.447706.199.0
8 pg
…She requests the deposition deadline be extended to July 30, 2016. The requested
relief would not disturb the trial date.
BACKGROUND
As the Court knows, this case was filed in September 2015. The Court’s original
scheduling order set the…
giuffre-maxwell
gov.uscourts.nysd.447706.1318.0
3 pg
…1314. On December 18, 2023, the Court issued the following docket
entry:
The Court reiterates here its previous recitation of the applicable
law and descriptions of the unsealing process set out in the
transcripts dated January 19, 2021 (dkt. no…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…Filed 08/09/16 Page 2 of 8
efforts to frustrate and evade the taking of his deposition. Instead of simply working with Ms.
Giuffre’s counsel to secure a mutually agreement date and time for Mr. Gow’s deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…model order, the
parties are required to discuss methods for search and review, including potential keyword
searches, date restrictions, and search backup files.
In short, a party’s responsibility to be forthcoming to reach agreed protocols concerning
ESI preservation, collection…
giuffre-maxwell
gov.uscourts.nysd.447706.56.0
14 pg
…N.Y. 2013).................................................................................................7
In re A2P SMS Antitrust Litigation,
972 F. Supp. 2d 465 (S.D.N.Y. 2013) .........................................................................................1
In re Grand Jury Subpoenas Dated March 24, 2003,
265 F. …
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…or treatment provided;
c. the dates You received consultation, examination, or treatment;
d. whether such treatment was on an in-patient or out-patient basis;
e. the medical expenses to date;
f. whether health insurance or some other person or…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.25
12 pg
…9 Q. That was their first time seeing him?
10 A. Yes.
11 Q. Had you ever seen him since that date?
12 A. No.
13 Q. And to thi…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…guardian or custodian, from
January 2015 to the present, including in such records date of purchase and amounts paid for
such securities, and certificates of any such securities.
RESPONSE: Ms. Maxwell objects to this Request on the grounds that it…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…NO
I ]I YES (DATE ADMITTED Mo. - - - Yr. _ _ _)
RECEIPli # Attorney Bar Code#
Magistrate Judge is to be designated by the Clerk of the Court.
Magi…