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.447706.1328.22
22 pg
…r entification Information (Fingerprints, palm
Information
1'19.071 (2)(e) Confession
3€>!5.171 (15) Identity of 911 reports are confidential for period of 60 days after
seHvice
1 'I …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…C entification Information (Fingerprints, palm
Information
C 1rn.071 (2)(e) Confession C ormants
C 3E>t,.171 (15) Identity of 911 reports are con…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…in this matter requires that, after an objection is made to a confidential
designation, the party seeking to protect the designation must file a motion within ten business
days of the date of the objection. See D.E. 62 at …
giuffre-maxwell
gov.uscourts.nysd.447706.1158.0
17 pg
…ECF No. 1157), and in light of
Does 1 and 2 not submitting any objection to unsealing within 14 days of being served with their
relevant excerpts, Plaintiff files excerpts of Doe 1’s deposition transcript (DEs 204-3, 212…
giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…to
intimidate, harass and cause undue burden to a non-party. Indeed, Defendant - just days ago -
publicly admitted that his goal of deposing Jane Doe No. 3 has nothing to do with this Florida
Defamation Action; rather, he is trying…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 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.447706.1295.10
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.447706.1331.26
5 pg
…A. I was present for his mother's --
4 his mother died in 2004 so I was there for
5 his mother's death and the funeral and I was
6 at the house maybe a handful of days, again…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…During the hearing, the Court granted in part, Ms. Giuffre’s Motion
to Compel. Now, twenty-six (26) days later, Defendant has still failed to produce any additional
documents. In contrast, to date, Ms. Giuffre has produced over 4,700…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.19
22 pg
…A Yes.
14 Q December 30th, 2014, correct?
15 A Yes.
16 Q And the corrected motion was filed a few
17 days later, correct?
18 A Yes, correct.
19 Q If I could turn to Defendant's Exhibit 3…
giuffre-maxwell
1320-19
22 pg
…A Yes.
14 Q December 30th, 2014, correct?
15 A Yes.
16 Q And the corrected motion was filed a few
17 days later, correct?
18 A Yes, correct.
19 Q If I could turn to Defendant's Exhibit 3…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 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.447706.1295.5
12 pg
…in that manner, Plaintiff should not be permitted to
1
course, Plaintiff’s Joinder Motion was followed three days later by the denial of Ms. Maxwell’s
press agent that forms the basis of this defamation action.). While the present…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…Second
Request for Production. See Schultz Decl. at Exhibit 1. In that letter, the undersigned proposed
we meet and confer call at Defendant’s counsel’s convenience over the next couple days. On
Monday, June 13, 2016, the following business…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.13_1
23 pg
…A Yes.
14 Q December 30th, 2014, correct?
15 A Yes.
16 Q And the corrected motion was filed a few
17 days later, correct?
18 A Yes, correct.
19 Q If I could turn to Defendant's Exhibit 3…
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…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.447706.35.0
31 pg
…See
McCawley Decl. at Exhibit 6, SAO 2830. Maxwell was also organizing “massages” for Epstein
in 2004 with underage girls and indicating which girls she had lined-up on given days. See
McCawley Decl. at Exhibit 6, SAO 02841.
Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…is proper at this time because, as of the date of
this filing, fact discovery closes in 17 days (although Ms. Giuffre has recently filed a motion for
a 30-day extension of the deadline). In order to give the…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…and his partner Sigrid McCawley, who represent several
witnesses in this matter, have also made public and presumptively prejudicial statements in
recent days, notwithstanding the fact that such conduct is prohibited by Local Rule 23.1, which
applies to lawyers…
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