giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…Fed. R.
Civ. P. 26(b)(1). Where discovery is sought from third parties, the Court must weigh the probative
value of the information against the burden of production on said non-party. In re Biovail Corp.
Sec. Litig., 247…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…Fed. R.
Civ. P. 26(b)(1). Where discovery is sought from third parties, the Court must weigh the probative
value of the information against the burden of production on said non-party. In re Biovail Corp.
Sec. Litig., 247…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Ms. Giuffre a “liar” and
Ms. Giuffre is now in the process of assembling testimony and evidence to prove the truth of her
allegations.
Apart from the Defendant in this case, Jeffrey Epstein is the most important person for
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
… Ms. Maxwell objects to the Requests to the extent they attempt to impose any
requirement or discovery obligation greater than or different from those under the Federal Rules
of Civil Procedure, the local rules of this Court or any Orders…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…Fed. R.
Civ. P. 26(b)(1). Where discovery is sought from third parties, the Court must weigh the probative
value of the information against the burden of production on said non-party. In re Biovail Corp.
Sec. Litig., 247…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…opinion, the Second Circuit suggested in dicta that “[t]he District Court may also
order the parties to identify and notify additional parties whose privacy interests would likely be
1
Based on lessons learned from past rounds of unsealing, the…
giuffre-maxwell
1320-8
12 pg
…Ms. Giuffre a “liar” and
Ms. Giuffre is now in the process of assembling testimony and evidence to prove the truth of her
allegations.
Apart from the Defendant in this case, Jeffrey Epstein is the most important person for
Ms…
giuffre-maxwell
1320-17
25 pg
… Ms. Maxwell objects to the Requests to the extent they attempt to impose any
requirement or discovery obligation greater than or different from those under the Federal Rules
of Civil Procedure, the local rules of this Court or any Orders…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…Ms. Giuffre a “liar” and
Ms. Giuffre is now in the process of assembling testimony and evidence to prove the truth of her
allegations.
Apart from the Defendant in this case, Jeffrey Epstein is the most important person for
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…INTRODUCTION
In her Second Request for Production of Documents, Plaintiff sought 21 categories of
personal financial information from the Defendant under the heading “Document Requests
Concerning Punitive Damages.” See Second Requests, attached to Declaration of Laura
Menninger (“Menninger Decl.”) as…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…MR. CASSELL: Of course it's our position that there
9 are email accounts and things like that, as you know from our
10 other papers, where we think -- so the fact that we have emails
11 on January 15…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…INTRODUCTION
In her Second Request for Production of Documents, Plaintiff sought 21 categories of
personal financial information from the Defendant under the heading “Document Requests
Concerning Punitive Damages.” See Second Requests, attached to Declaration of Laura
Menninger (“Menninger Decl.”) as…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
… Ms. Maxwell objects to the Requests to the extent they attempt to impose any
requirement or discovery obligation greater than or different from those under the Federal Rules
of Civil Procedure, the local rules of this Court or any Orders…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…at Issue
Both Ms. Maxwell and J. Doe selectively quote from the Second Circuit’s ruling in Brown
v. Maxwell in an attempt to minimize the right of access that attaches to all judicial documents. In
2
At the outset…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…INSTRUCTIONS
1. Unless indicated otherwise, the “Relevant Period” for this Request is from 1999
to the present. A Document should be considered to be within the relevant time frame if it refers
or relates to communications, meetings or other events…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…Page 2 of 2
(PLACE AN x IN ONE BOX ONLY) ORIGIN
~ 1 Ori ginal D 2 Removed from Remanded D 4 Reinstated or D 5 Transferred from D 6 Mullidistrict D 7 Appeal to District
Proceeding State Court …
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