giuffre-maxwell
gov.uscourts.nysd.447706.1331.29
4 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
1320-40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…HBP, 2012 WL 4791804,
at *6 (S.D.N.Y. Oct. 9, 2012) (failure to make any attempts to resolve any specific
discovery disputes “alone is a sufficient ground for denying the motion [to compel]”);
Prescient Partners, L.P. v…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…discussions with David
Boies. Counsel for Ms. Roberts plainly instructed Dershowitz that these matters were confidential
and, if that was disputed, the issue needed to be presented to a judge for resolution.
MS. McCA WLEY: Again, I'm going to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Maxwell’s deposition (which depended, among other
things, on an historic snowstorm, a disputed protective order, Plaintiff’s failure to timely produce
documents, and counsel’s conflicting calendars, all of which have been amply documented with
this Court)4 does…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.20
14 pg
…is received, it shall be the obligation of the party designating the
information as CONFIDENTIAL to file an appropriate motion requesting that the
Court determine whether the disputed information should be subject to the terms
of this Protective Order. If…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…the Court ordered that prior to motions practice, the
parties were to set an agenda on the disputed issue in writing and have a meeting of substance
prior to filing a motion. “So I would say exchange writing as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.2
23 pg
…Tel.
Corp., 594 F.2d 291, 295 (2d Cir. 1979). They promote “the ‘secure the just, speedy, and
inexpensive determination’ of civil disputes, by encouraging full disclosure of all evidence.” Id.
(quoting Fed. R. Civ. P. 1). “If protective orders…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…40
Korein Tillery
(http://www.americanlawyer.com/home/id=1202754670719)
$50,000 Punitive Award Given in Attorney Fee Dispute
(http://www.dailybusiness…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…the Court ordered that prior to motions practice, the
parties were to set an agenda on the disputed issue in writing and have a meeting of substance
prior to filing a motion. “So I would say exchange writing as to…
giuffre-maxwell
gov.uscourts.nysd.447706.562.2
29 pg
…ARGUMENT
II. EDWARDS AND CASSELL ARE ENTITLED TO PARTIAL SUMMARY
JUDGMENT ON THE PENDING PRIMARY CLAIM BECAUSE THERE
ARE NO MATERIAL DISPUTED FACTS AND THE UNDISPUTED FACTS
ESTABLISH THAT DERSHOWITZ REPEATEDLY BROADCAST FALSE
AND DEFAMATORY STATEMENTS ABOUT THEM.
…
giuffre-maxwell
gov.uscourts.nysd.447706.849.0
94 pg
…7 report itself coming in. And even if it were to come in, it's
8 unclear why anything in the report is relevant to a disputed
9 fact in our case. We don't know what she reported. We…
giuffre-maxwell
gov.uscourts.nysd.447706.847.0
94 pg
…7 report itself coming in. And even if it were to come in, it's
8 unclear why anything in the report is relevant to a disputed
9 fact in our case. We don't know what she reported. We…
giuffre-maxwell
1320-28
32 pg
…Maxwell’s deposition (which depended, among other
things, on an historic snowstorm, a disputed protective order, Plaintiff’s failure to timely produce
documents, and counsel’s conflicting calendars, all of which have been amply documented with
this Court)4 does…
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…civil proceedings once they were commenced. They are
therefore privileged. It is not disputed that the AIT investigation and reports also
address lessons that could be learned from the incident and fulfilled COMAH
requirements. However, for the reasons already explained…
giuffre-maxwell
gov.uscourts.nysd.447706.730.0
14 pg
…reported her allegations of sex abuse and sex trafficking to federal law
enforcement agents in 2011, well before the disputed events in this case occurred. The jury may
use that fact of a prior report to law enforcement as one…
giuffre-maxwell
gov.uscourts.nysd.447706.22.0
14 pg
…it must be clear on the record that no dispute exists regarding the
authenticity or accuracy of the document…It must also be clear that there exists no material
disputed issues of fact regarding the relevance of the document…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…Maxwell 's deposition (which depended, among other
things, on an historic snowsto1m, a disputed protective order, Plaintiffs failure to timely produce
documents, and counsel 's conflicting calendars, all of which have been amply documented with
this Comi)4 does not…
giuffre-maxwell
gov.uscourts.nysd.447706.936.0
21 pg
…to Section 6.2 of
the Electronic Case Filing Rules & Instructions for the Southern
District of New York.
***
A party may object to the designation of particular
CONFIDENTIAL INFORMATION by giving written notice to the
party designating the disputed