giuffre-maxwell
gov.uscourts.nysd.447706.1034.0
16 pg
…1026, 1028, 1029,
1030.) The Court rules as follows:
1. Decided Motions: The parties disputed whether two motions
(dkt. nos. 468, 567) were actually decided by Judge Sweet and
thus disagreed as to whether they should be included on the…
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
gov.uscourts.nysd.447706.1327.4
4 pg
…P. 26(a)(l)(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.447706.526.0
5 pg
…831.7364
Case 1:15-cv-07433-LAP Document 526 Filed 01/05/17 Page 2 of 5
TABLE OF CONTENTS
INTRODUCTION .......................................................................................................................... 1
ARGUMENT ..........................................…
giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…2017;
The Revised Joint Pre-trial Order shall be submitted by April 15, 2017;
Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by
April 24, 2017;
Proposed jury questions shall be submitted by May 1, 2017…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.15
11 pg
…party may object to the designation of particular
CONFIDENTIAL INFORMATION by giving written notice to the party
designating the disputed information… it shall be the obligation of the party
designating the information as CONFIDENTIAL to file an appropriate motion
…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.23
10 pg
…Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply
at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms. Giuffre was
the child victim of sexual abuse. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.542.0
7 pg
…flew to Britain to meet him,”
DAILY MAIL, dated March 2, 2011.
1
At trial, defendant intends to produce either the custodian of record relevant to any
disputed document or a certification in compliance with either Fed. R. Evid. P…
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.447706.140.3
4 pg
…at issue; rather, an in camera
assessment of the disputed documents was deemed necessary to weigh whether the particular requested documents are
shielded by a public-interest privilege against disclosure of confidential communications. 4
The public interest privilege applied, in…
giuffre-maxwell
gov.uscourts.nysd.447706.455.0
4 pg
…2017;
Motions in Limine/other motions shall be filed by February 24, 2017;
Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by
February 24, 2017;
Proposed jury questions shall be submitted by March 3, 2016.
WHEREFORE…
giuffre-maxwell
gov.uscourts.nysd.447706.992.0
5 pg
…as here, the disputed documents are
filed in support of or in opposition to a discovery motion other than a motion as to the
discoverability or confidentiality of the disputed documents themselves, they are properly
Case 1:15-cv…
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.447706.335.0
13 pg
…at ¶ 8. The Order continues:
A party may object to the designation of particular CONFIDENTIAL INFORMATION by
giving written notice to the party designating the disputed information. The written notice
shall identify the information to which the objection is made…
giuffre-maxwell
gov.uscourts.nysd.447706.140.2
3 pg
…be invoked when the government itself brings suit.7 However, the conclusory assertion of a general harm to the public
good if the disputed documents are disclosed is inadequate to justify invoking the public interest privilege; there must be
proof…
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…
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