giuffre-maxwell
gov.uscourts.nysd.447706.1111.0
69 pg
…and 872]; and (b) all unfiled discovery deposition transcripts and exhibits
thereto. The USVI seeks to modify the Protective Order [ECF No. 62] solely to be granted
confidential access to these materials, and, if granted access, agrees to be bound…
giuffre-maxwell
gov.uscourts.nysd.447706.89.0
10 pg
…Giuffre. For the
reasons set forth below, this Court should deny both of Defendant’s Letter Motions, and grant
Professor Cassell and Mr. Edward’s Motions to Appear Pro Hac Vice.
I. PROCEDURAL HISTORY
Upon Defendant’s April 6, 2016…
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.447706.1330.8
10 pg
…party deposition is appropriate where
important documents are produced after the deposition is completed. Accordingly, the Court should
grant Ms. Giuffre’s request to reopen Defendant’s deposition to answer questions relating to her
lately produced documents.
I. BACKGROUND
The…
giuffre-maxwell
gov.uscourts.nysd.447706.1048.0
2 pg
…Lebowitz on behalf of
Intervenor Alan M. Dershowitz.
Dated: March 31, 2020
New York, New York
KAUFMAN LIEB LEBOWITZ &
FRICK LLP
The motion to withdraw is granted. By: /s/
SO OR…
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.447706.1219.1
18 pg
…18, and Motion to Compel Production of certain documents on Defendant’s Third
Amended Privilege Log. For the reasons set forth below, this Court should grant Plaintiff’s
Motion in its entirety.
I. FACTUAL BACKGROUND1
1
On Wednesday, June 8…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…04 a.m., and to strike Defendant's affidavit, pleadings and
grant attorney's fees to Virginia Roberts, and hereby states as follows.
INTRODUCTION
Alan Dershowitz intentionally and wrongfully submitted a misleading affidavit to this
Court, kn…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…of non-public, on-going law enforcement investigations. Nor is there any
good reason for the Court to grant a last-minute “stay” of this case (including Defendant’s long-
delayed deposition, which is currently scheduled for Friday). Defendant has…
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.447706.9.0
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.447706.1320.25
4 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.447706.1294.0
11 pg
…others, Doe 171
(“November 18 Order”). (Dkt. no. 1283.) On November 19, 2022,
the Court granted Doe 171 a stay through December 5, 2022,
pending appeal, of the release on documents relating to her.
(Dkt. no. 1275.) On November 30…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.22
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.447706.1090.23
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.447706.1256.6
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.447706.540.0
3 pg
…Sweet, for an order pursuant to Federal Rule of Civil Procedure 56 and
Local Civil Rule 56.1, granting Defendant’s motion for summary judgment and dismissing the
Complaint filed on September 21, 2015 in its entirety with prejudice. The…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.39
5 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
1320-22.2
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
1320-25
4 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…
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