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.447706.1201.17
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.447706.204.0
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.447706.684.0
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.447706.733.0
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.447706.1200.2
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.447706.1331.1
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.447706.1330.12
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…
giuffre-maxwell
gov.uscourts.nysd.447706.651.0
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.447706.311.0
3 pg
…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 Support of Plaintiff Virginia Giuffre’s…
giuffre-maxwell
gov.uscourts.nysd.447706.409.2
1 pg
…Goldberger, 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 of the State
of Florida; and that his contact information is…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.34
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.447706.97.0
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.447706.1219.44
4 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.447706.1292.0
2 pg
…the Second Circuit—contain
information that Doe 171 is presently fighting and exercising her appellate rights to
keep under seal. In light of the Second Circuit’s Order entered today granting a stay
pending Doe 171’s appeal (Doc. 1291)…
giuffre-maxwell
gov.uscourts.nysd.447706.690.0
3 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.447706.471.0
3 pg
…am 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…
giuffre-maxwell
gov.uscourts.nysd.447706.564.0
3 pg
…I am 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…
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