giuffre-maxwell
gov.uscourts.nysd.447706.345.0
18 pg
…respectfully submits
this Motion to Compel Production of Documents
For the reasons set forth below, this Court should grant Plaintiff’s
Motion in its entirety.
I. FACTUAL BACKGROUND1
1
Case 1:15-cv-07433-LAP Document 345 Filed 08/09…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…be served for his deposition will not prejudice the Defendant and will serve the search for
truth. Ms. Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
It is undisputed that Mr. Gow is a key witness in this case…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…Motion to Stay Discovery during the pendency of her Motion to Dismiss.
LEGAL STANDARD
Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to stay
discovery “for good cause shown.” Spencer Trask Software and Info…
giuffre-maxwell
gov.uscourts.nysd.447706.204.0
3 pg
…and duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Support of Plaintiff’s Reply…
giuffre-maxwell
gov.uscourts.nysd.447706.112.2
1 pg
…Cassell, for admission to practice Pro Hac Vice in the above captioned action is
granted.
Applicant has declared that he is a member in good standing of the bar(s) and the state of Utah; and that his
contact information…
giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this…
giuffre-maxwell
gov.uscourts.nysd.447706.9.0
3 pg
…_, for admission to
practice Pro Hae Vice in the above captioned action is granted.
Applicant has declared that he/she is a member in good standing of the bar(s) of the state(s) of
Florida _ ; and that his/her…
giuffre-maxwell
gov.uscourts.nysd.447706.140.0
4 pg
…duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in support of Plaintiff Virginia Giuffre’s…
giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…with the law firm of Boies, Schiller & Flexner LLP and duly licensed to
practice in Florida and before this Court pursuant to this Court’s Order granting my Application
to Appear Pro Hac Vice.
2. I respectfully submit this Declaration…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…with the law firm of Boies, Schiller & Flexner LLP and duly licensed to
practice in Florida and before this Court pursuant to this Court’s Order granting my Application
to Appear Pro Hac Vice.
2. I respectfully submit this Declaration…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.17
4 pg
…Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this…
giuffre-maxwell
gov.uscourts.nysd.447706.1265.0
2 pg
… :
:
Defendant. :
:
----------------------------------------------------------x
[PROPOSED] ORDER GRANTING MOTION FOR ADMISSION PR…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.10_2
4 pg
…with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29,
2015 Order granting my Application to Appear Pro Hac Vice.
2. I respectfully…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
3 pg
…duly
licensed to practice in Florida and before this Court pursuant to this Court’s September 29, 2015
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Support of Plaintiff’s Motion for…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.2
3 pg
…and duly
licensed to practice in Florida and before this Court pursuant to this Court’s March 28, 2016
Order granting my Application to Appear Pro Hac Vice.
2. I respectfully submit this Declaration in Plaintiff’s Motion for An…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.11
5 pg
…associate with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.1
3 pg
…I am an associate with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.14
4 pg
…a Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.8
4 pg
…Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit this…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.12
4 pg
…a Partner with the law firm of Boies, Schiller & Flexner LLP and duly
licensed to practice in Florida and before this Court pursuant to this Court’s Order granting my
Application to Appear Pro Hac Vice.
2. I respectfully submit…