giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms.
Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware,
all of this…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Defendant’s arguments change the questions Defendant refused to answer. Accordingly, Ms.
Giuffre’s motion should be granted.
I. PRELIMINARY STATEMENT
Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware,
all of this…
giuffre-maxwell
gov.uscourts.nysd.447706.27.1
3 pg
…as Revised. The Court has carefully considered
the Motion, and being otherwise fully advised in the premises, it is ORDERED AND
ADJUDGED that the motion is hereby GRANTED.
Plaintiff’s counsel, Sigrid S. McCawley shall be permitted, to bring and…
giuffre-maxwell
gov.uscourts.nysd.447706.27.0
3 pg
…by and through undersigned counsel, hereby moves this Court for an Order
granting Plaintiff’s counsel leave to bring Personal Electronic Devices and General Purpose
Computing Device into the Courthouse for the hearing currently scheduled for January 14, 2016,
in…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.18
5 pg
…Espinoza
Farmer
Ward
x Fekkai
x Figueroa
x Fontanilla
x Friedman
x Gibson-Butte
x Gramza
x Gany
x Grant
x Groff
3
Case 1:15-cv-07433-LAP Document 1327-18 Filed 01/05/24 Page 5 of…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may “at any time”
add new parties to the action…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…2022 Hr’g Tr. at 7 (“Hr’g Tr.”) (this Court granting such relief as to Doe 28).
Based on the information available to us, Doe 171’s requested relief pertains to at
most 13 of the of the 29…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…opposed this protocol
1
A decision on whether to grant Dershowitz’s motion for leave to file his proposed
motion to compel Giuffre “and others” to produce discovery could have a substantial and real-
time effect on the ongoing unsealing…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…hereby files this reply
in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…hereby files this reply
in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1286.0
6 pg
…2022 Hr’g Tr. at 7 (“Hr’g Tr.”) (this Court granting such relief as to Doe 28).
Based on the information available to us, Doe 171’s requested relief pertains to at
most 13 of the of the 29…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…hereby files this reply
in suppo1i of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may “at any time”
add new parties to the action…
giuffre-maxwell
gov.uscourts.nysd.447706.406.0
31 pg
…Modifying Protective Orders
Upon Which Parties Reasonably Relied ............................................................... 20
1. The Record in this Case Shows That the Protective Order Was Not
Improvidently Granted....................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…relevance whatsoever to any issue in this case. Of course,
given the broad scope of discovery, the Court can grant Defendant’s motion only if no relevance
exists at all. But in fact, Defendant’s financial information is highly relevant…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
1320-21
15 pg
…hereby files this reply
in support of her Motion to Exceed Presumptive Ten Deposition Limit. The motion should be
granted because Ms. Giuffre has shown good cause for needing to exceed the ten deposition limit
and in light of recent…
giuffre-maxwell
1320-9
10 pg
…current victims
(and because they are represented by the same legal counsel as the current victims), the
Government will not be prejudiced if the Court grants the motion. The Court may “at any time”
add new parties to the action…