giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…23/17 Page 2 of 4
The Parties, through their respective counsel, propose the following case management
deadlines and request that the Court enter an order modifying its Order of October 3, 2016, ECF
#455 for the following reasons:
Subsequent…
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.447706.455.0
4 pg
…451 Filed 09/30/16 Page 2 of 4
The Parties, through their respective counsel, propose the following discovery and case
management deadlines and request that the Court enter an order modifying its Order filed
October 30, 2015 , ECF #13 …
giuffre-maxwell
gov.uscourts.nysd.447706.116.0
6 pg
…AND EDWARDS’
RENEWED MOTIONS TO APPEAR PRO HAC VICE
Defendant Ghislaine Maxwell, by and through her attorneys, hereby submits the
following opposition to Messrs. Cassell and Edwards’ Renewed Motions to Appear Pro Hac
Vice in this Matter (Doc. #112 - 115)…
giuffre-maxwell
gov.uscourts.nysd.447706.1008.0
5 pg
…Cir. 2006) (holding that documents
submitted with a motion are “unquestionably judicial documents” “by virtue of having been
submitted to the court”). For the following reasons, the Court should hold that materials submitted
in support of motions are judicial documents…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…7. Documents are designated as CONFIDENTIAL by placing or affixing on them
(in a manner that will not interfere with their legibility) the following or other
appropriate notice: “CONFIDENTIAL.” Discovery material designated
CONFIDENTIAL shall be identified by Bates number. To…
giuffre-maxwell
gov.uscourts.nysd.447706.841.0
6 pg
…SERVICE
I certify that on April 11, 2017, I electronically served this Defendant’s Reply in Support of
Objection to Production of Submitted for in Camera Review via
ECF on the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1026.2
4 pg
…process and afford persons identified or
otherwise interested in the Sealed Materials the opportunity to participate in the Court’s
individualized review, the Court adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.806.0
6 pg
…of 6
CERTIFICATE OF SERVICE
I certify that on March 28, 2017, I electronically served this Objection to Production of
Submitted for in Camera Review via ECF on the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.215.0
2 pg
…2016 (the first Thursday following the
completion of briefing) or a later date convenient for the Court.
DWT 29803975v1 0085000-002358
Case 1:15-cv-07433-LAP Document 215 Filed 06/15/16 Page 2 of 2
Dated: New…
giuffre-maxwell
gov.uscourts.nysd.447706.1108.0
5 pg
…process and afford persons identified or otherwise interested in the
Sealed Materials the opportunity to participate in the Court’s individualized review, the Court
adopts the following protocol.
1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell
(collectively…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…12
CERTIFICATE OF SERVICE
I certify that on October 24, 2016, I electronically served this Defendant’s Response to
Plaintiff’s Motion to Reopen Defendant’s Deposition via ECF on the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
… During that time
10 it was the elections, so there was a
11 lot more other things going on.
12 There were two people
13 following me after I came forward to
14 Maureen Callahan. I went to -- I
15…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…in
support of and against summary judgment. Ultimately, the rationale of the denial of unsealing was
boiled down to the following countervailing factors:
1
Available at: (last accessed Apr. 19…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…diminishing the required individualized
review and the Protocol. The following suggestions are inclusive of those in our August 4 letter,
Case 1:15-cv-07433-LAP Document 1228 Filed 08/10/21 Page 3 of 4
August 10, 2021
…