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.447706.1327.4
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
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.447706.542.0
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.447706.455.0
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.447706.335.0
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.447706.1199.1_1
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.447706.1332.3
21 pg
…in her current briefing. In
claiming that Ms. Giuffre has somehow failed to confer, Defendant does not suggest that any
conferral would have narrowed the disputed issues before the Court. Ms. Giuffre believes
Defendant has waived privilege; Defendant simply disagrees…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 pg
…Indent: Left: 0.5", No
bullets or numbering
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 …
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.447706.26.1
26 pg
…Elizabeth S. Zuckerman, Based on the content of the complaint, which Defendant
Jeffrey E. Poindexter, Bulkley, Richardson & Gelinas, has not disputed, the court finds Defendant is a citizen of
John J. Egan, Egan, Flanagan & Cohen, PC, Springfield, Massachusetts and Plaintiffs…
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.447706.535.0
18 pg
…of an expert witness is only admissible if it (1) assists the trier
of fact in (2) understanding the evidence or determining a disputed fact.”) (emphasis in original).
In deciding whether expert testimony will be helpful to the fact-finder…
giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…privacy, and (3)
requesting excerpts of sealed materials that mention them for their
review (the “September 25 Email”).
The parties dispute the procedural import of the September 25
Email under the Protocol governing the unsealing of documents in
this action…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.3_1
2 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1006.0
1 pg
…agreement as to all of the decided motions with the exception
of two motions.
The first motion in dispute is ECF 567 Defendant’s Motion in Limine to Exclude In Toto
Certain Deposition Designated by Plaintiff for Use at Trial…