gov.uscourts.nysd.447706.1328.44.pdf PDF
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…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF VIRIGINA GIUFFRE IN AN UNRELATED CASE …
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF VIRIGINA GIUFFRE I…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCLUDE DEFENDANT’S DESIGNATION OF DEPOSITION EXCERPTS OF ALAN DERSHOWITZ IN A…
…be maintained as confidential. Pursuant to the Court’s Protective Order, Ms. Giuffre marked as confidential highly sensitive documents and Defendant is now challenging that designation. Defendant objects to maintaining as confidential police reports involving Ms. Giuffre, including two police…
…Re: Giuffre v. Maxwell Dear Ms. Schultz: Pursuant to paragraph 11 of the Protective Order in this case Ms. Maxwell disputes the confidential designation of documents produced by Ms. Maxwell to the Plaintiff, GM 748-849. Your email does not…
…extension of time to respond to "Plaintiffs Motion to Exclude Designation of Deposition Excerpts of Alan Dershowitz in an Unrelated Case" (ECF 561) and "Plaintiffs Motion to Exclude Defendant's Designation of Deposition Excerpts of Virginia Giuffre in an Unrelated…
…a mechanism by which the parties may designate as “confidential” documents that would warrant protection under Federal Rule of Civil Procedure 26(c). The designation is important, since it confers upon the document the Court’s imprimatur that, in fact…
…of a Protective Order in this case, but does oppose a Protective Order in the form proposed by Defendant because it is overly broad and can lead to abuse and over designation of material as “confidential.” Ms. Giuffre’s proposal1…
…from when she was a child, some of them concerning her being raped when only 14 years. Defendant’s challenge to Ms. Giuffre’s confidentiality designation is without merit, and it is for improper purposes. Therefore, it should be denied…
…seek to overturn the protective order as follows: “The Protective Order states that parties can object to the confidentiality designations: “A party may object to the designation of particular CONFIDENTIAL INFORMATION by giving written notice to the party designating the…
…Intervenor’s June 21, 2017 letter and its attachments, and remove the confidentiality designation from several related emails and attachments that the parties previously designated confidential (RANSOME_000273-557) (“the Emails”). The Emails will demonstrate that Ms. Ransome’s inflammatory…
…that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a motion in…
…all Formatted: Font: 12 pt, Font color: Black Formatted: Indent: First line: 0.5", Space disclosures during discovery. Designations under this Order shall be made sparingly, with care, Before: 0 pt, Line spac…
…if the Court allows Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails…
…review the designated testimony in light of such rulings and then address any unresolved designation objections. The parties expect to submit in the next few days a proposed schedule for hearings on remaining legal issues in this matter and a…
…if the Court allows Plaintiff Virginia Giuffre to remove the confidentiality designation concerning the Ransome deposition—an action that would require modification of the Protective Order in this case —it also simultaneously remove the confidentiality designation from several related emails…
…be placed near the Bates number. 8. Designation of a document as CONFIDENTIAL INFORMATION shall constitute a representation that such document has been reviewed by an attorney for the designating party, that there is a valid and good faith basis…
…fairly obvious that this is fishing with a drift net. We decline your request to engage in this exercise. Regarding redacted police reports that plaintiff designated “confidential”: We objected to plaintiff’s confidentiality designation, and plaintiff failed to file a …
…Giuffre, Plaintiff, Case No: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS AND PLAINTIFF’S CROSS DESIGNATIONS Plaintiff Virginia Giuffre…
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