giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
1320-28
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…waiver. In any event, whether served or not, Mr.
Brunel apparently promised to provide new dates before his deposition date came and went, did
not do so, has left the country and not indicated a present intention to return. Given…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…the
5 Court I didn't think so, and I didn't think that the trial date
6 was reasonable as a result of what I perceived to be problems
7 going forward with discovery. Counsel on the other side…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.22
31 pg
…with that Order. The parties are further directed to jointly file a proposed redacted version
of this Opinion or Notify the Court that none are necessary within two weeks of the date of receipt of this Opinion.”
June 20, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.156.1
26 pg
…msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016
Case 1:15-cv-07433-LAP Document 156-1 Filed 05/20/16 Page 3 of 26
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.1326.3
27 pg
…msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016
Case 1:15-cv-07433-LAP Document 1326-3 Filed 01/04/24 Page 3 of 27
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.1320.15
27 pg
…msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016
Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 3 of 27
Log …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…attorneys n interest Withheld 2 msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated June 9, 2016
Log …
giuffre-maxwell
1320-15
27 pg
…msg
Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016
Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 3 of 27
Log …
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.447706.40.0
8 pg
…to sit for her deposition. See McCawley
Decl. at Exhibit 3, (E-mail from Laura Menninger stating: “We have not and will not accept the
date of March 25, or any other date, for Ms. Maxwell’s deposition until a…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…data, and requests that this Court enter an adverse inference jury instruction for this
willful violation of this Court’s orders.
I. BACKGROUND
The earliest-dated email Defendant has produced in this litigation is from July 18, 2009.
(GM_00069)…
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.447706.1200.14_1
11 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.447706.1295.8
9 pg
…her deposition.
BACKGROUND
On February 6, 2017, Defendant served non-party witness Sarah Ransome with a
subpoena that included 30 different document requests and set her compliance date for just seven
(7) days later on February 13, 2017. In addition…