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…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…First Set of Discovery Requests to Plaintiff Virginia Giuffre. Plaintiff shall
respond in writing to the Interrogatories, and shall produce documents as requested, within thirty
(30) days of service at the offices of Haddon, Morgan & Foreman, P.C., 150 E…
giuffre-maxwell
gov.uscourts.nysd.447706.17.1
13 pg
…East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida
33301, within thirty (30) days of service hereof.
DEFINITIONS
Wherever they hereafter appear the following words and phrases have the following
meanings:
1. “Agent” shall mean any agent, employee, officer, director…
giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…1108.) The Protocol provides that, within
14 days of service of excerpts upon a non-party, the relevant non-
party may submit to the Court an “objection” to unsealing which
“[states] briefly the reasons for the objection” and “[identifies]
any…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…request for production over the
1
Case 1:15-cv-07433-LAP Document 1200-1 Filed 01/27/21 Page 2 of 8
aforementioned ESI and produce responsive documents within 21 days of distribution of this
opinion.
June 20…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.10
14 pg
… In a hotel.
20 Q. And how long did you spend
21 with Mr. Pottinger on that occasion?
22 A. Two days.
23 Q. How many hours over the two
24 days?
25 A. Gosh, about 16.
Highly Confidential…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…Plse reach out to him today
+ I have already suffered such a terrible and painful loss over the last few days that I can't even see what life
after press he'll even looks like - statements that don…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…Court, they filed their
objection to unsealing, and the Original Parties therefore have 7 days to respond to that objection
or to file their own objection to unsealing the five motions at issue pursuant to the Protocol. ECF
No. 1109…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.22
22 pg
…Plse reach out to him today
+ I have already suffered such a terrible and painful loss over the last few days that I can't even see what life
after press he'll even looks like - statements that don…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
Local Civil Rule 33.3(b)…
giuffre-maxwell
gov.uscourts.nysd.447706.131.0
3 pg
…Ms. Giuffre
1
Case 1:15-cv-07433-LAP Document 131 Filed 05/01/16 Page 2 of 3
respectfully requests that the Court stay its ruling for twenty (20) days to allow Ms. Giuffre an
opportunity to consult…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
… 2(d), “[w]ithin 14 days of service of the Excerpts, the Non-Party may submit
to the Court an objection.” Any such “objection” must “state briefly the reasons for the
objection and identify any countervailing interest that militates against…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
Local Civil Rule 33.3(b)…
giuffre-maxwell
1320-37
48 pg
…because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…because they are not “a more practical
method of obtaining the information sought than a request for production or a deposition,” and
because they were served in advance of the period “30 days prior to the discovery cut-off date.”
…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…2002 to present.
Defendant is further directed to run mutually- agreed upon search terms related
to Plaintiff's requests for production over the aforementioned ESI and produce
responsive documents within 21 days of distribution of this opinion.
On June 30…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…to present. Defendant is further directed
to run mutually- agreed upon search terms related to Plaintiff's requests for production
over the aforementioned ESI and produce responsive documents within 21 days of
distribution of this opinion.
This was done. Plaintiff…
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