giuffre-maxwell
gov.uscourts.nysd.447706.1219.10
4 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of August 1, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.6
4 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of August 1, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.1331.21
8 pg
…The Southern District of New York
Giuffre v. Maxwell
15-cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE D…
giuffre-maxwell
gov.uscourts.nysd.447706.986.0
60 pg
…Court
500 Pearl Street
New York, NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-07433-LAP
Dear Judge Preska:
Plaintiff submits the following categories of documents pursuant to the Court’s Order of
September 5, 2019. Dkt. 982…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…more efficiently without becoming unduly burdensome. The Original Parties therefore
present the following options to the Court.
Plaintiff’s Proposal
Plaintiff proposes beginning to address Non-Party objections in the next round of
unsealing, rather than first finishing the remaining…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.35
7 pg
…when and where the following proceedings were
reported by:
Michele Cameron
Magna Legal Services
866-624-6221
Case 1:15-cv-07433-LAP Document 1218-35 Filed 07/15/21 Page 3 of 7
…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.13_1
3 pg
…letter is a follow-up to our conferral on July 26, 2016.
Regarding plaintiff’s RFP 12, we are supplementing with the following based
on your letter of June 8, 2016. The RFP requires defendant to “produce all
documents concerning…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…1108. The Parties met and conferred on July 26, and discussed
ways in which the sealing process can proceed more efficiently. The Parties therefore present the
following options to the Court.
Plaintiff’s Proposal
At the July 1, 2021, hearing…
giuffre-maxwell
gov.uscourts.nysd.447706.34.1
6 pg
…The Southern District of New York
Giuffre v. Maxwell 15-
cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
TAB …
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…Plaintiff, forthwith, to deliver any “materials” to
the Defendant for the following reasons:
For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her
claim that there is an ongoing and active criminal investigation in which Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.43
12 pg
…date. Defendant represents to the Court that there is no
undisclosed email address, yet in the following sentence, she begins a three-page description of her
undisclosed email account on Epstein’s server that she says she cannot access. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.16
3 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of May 16, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.55.11
3 pg
…The Southern District of New York
Giuffre v. Maxwell
15-cv-07433-RWS
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
DATE D…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.5_1
3 pg
…This letter is a follow-up to our conferral on July 26, 2016.
Regarding plaintiff’s RFP 12, we are supplementing with the following based
on your letter of June 8, 2016. The RFP requires defendant to “produce all
documents…
giuffre-maxwell
gov.uscourts.nysd.447706.223.2
7 pg
…April 07, 2016 12:01 PM
To: Martin Weinberg
Subject: RE: Giuffre v. Maxwell
No -I can wait until tomorrow. Thank you for following up.
Sigrid
Sigrid S. McCawley·
Partner
BOIES, SCHILLER & FLEXNER LLP
401 East Las Olas Blvd., Suite…
giuffre-maxwell
gov.uscourts.nysd.447706.139.0
7 pg
…Giuffre, by and through her undersigned counsel, respectfully submits
the following authority for the application of the privilege claimed regarding her in camera
submission, pursuant to the Court’s Order [DE 134] dated May 2, 2016.1
ARGUMENT
Statements made…
giuffre-maxwell
1320-16
3 pg
…RWS
Ghislaine Maxwell’s Privilege Log Amended as of May 16, 2016
***Per Local Rule 26.2, the following privileges are asserted pursuant to British law, Colorado law and NY law.
Log ID DATE DOC. BATES FROM …
giuffre-maxwell
gov.uscourts.nysd.447706.542.5
11 pg
…3 and Jane Doe 4 as Petitioners (" Rule 15 Motion") ( DE
311). Both motions are ripe for review. For the following reasons, the Court concludes that they
should be denied.
I. Background
This is an action by two unnamed petitioners…
giuffre-maxwell
gov.uscourts.nysd.447706.1052.0
4 pg
…NY 10007
Re: Giuffre v. Maxwell,
Case No. 15-cv-7433-LAP
Dear Judge Preska,
The Original Parties jointly write to seek clarification of the following parts of the Protocol
for Unsealing Decided Motions, ECF No. 1044:
at a time…