giuffre-maxwell
gov.uscourts.nysd.447706.1110.0
2 pg
…Preska, for an order pursuant to Federal Rule of Civil Procedure
24 granting the USVI’s motion to intervene and for confidential access to judicial records and
discovery documents. The grounds for this motion are set forth in the accompanying…
giuffre-maxwell
gov.uscourts.nysd.447706.69.0
4 pg
…Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s
Response in Opposition to Defendant’s Motion to Compel Plaintiff to Disclose Pursuant to
Federal Rule of Civil Procedure [D.E. 64].
3…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.16
22 pg
…and upon information and belief as to all other
matters, as follows:
1. This cause of action arises under federal statutes and jurisdiction is
proper under 28 U.S.C. $ 1331.
2. Plaintiff files this Complaint under a pseudonym…
giuffre-maxwell
gov.uscourts.nysd.447706.215.0
2 pg
…Southern District of New York, for an order pursuant to Rule 45(d)(3) of
the Federal Rules of Civil Procedure quashing the subpoena served by defendant Ghislaine
Maxwell on non-party Sharon Churcher, and for such other and further…
giuffre-maxwell
gov.uscourts.nysd.447706.362.0
2 pg
…or as soon thereafter as
counsel may be heard, for permission to intervene in this action pursuant to Federal Rule of Civil
Procedure 24(b), and for an Order unsealing certain documents previously filed with the Court,
or in the…
giuffre-maxwell
gov.uscourts.nysd.447706.940.0
1 pg
…against - : Case No. 15-cv-7433 (RWS)
:
GHISLAINE MAXWELL, :
:
Defendant. :
…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Case No. 08-80736-CIV-
MARRA/JOHNSON, [ECF No. 291-1] (the “Federal Action”).
2. All photographs and video in the original, native format in which they were taken (not a
paper copy) of you with Alan M. Dershowitz.
3…
giuffre-maxwell
gov.uscourts.nysd.447706.1262.1
2 pg
…Code (Title 28, U.S.C.) which pertain to the
jurisdiction of, and practice in, the United States District Courts;
b. The Federal Rules of Civil Procedure;
c. The Federal Rules of Criminal Proce…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…1s1 ( ] 430 BAN KS & BANKING
INS TRUMENT SLANDE:R ( J 368 ASBESTOS PERSONAL I J S 0 OTHER I I 450 COMMERCE
I J 150 RE COVERY OF [ J 330 FEDERAL INJURY PRODUCT …
giuffre-maxwell
gov.uscourts.nysd.447706.216.8
4 pg
…Prince Andrew, and Clinton, and reveals that she has instructed her
lawyers — who include former federal judge, Paul Cassell, and victims’ rights expert Bradley Edwards — to bring the men
to justice.
“I have directed my attorneys … to pursue all…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
1320-37
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1290.0
3 pg
…18, 2022 ruling identified Doe 171 by name as Emmy Tayler. That ruling
discussed how “on July 19, 2022, Doe 171 filed a federal lawsuit against Julie Brown, the reporter,
and Harper Collins, alleging that Ms. Brown’s book, Perversion…
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