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.447706.1219.1
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.447706.1328.29
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.447706.1090.3_1
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.447706.1320.25
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.447706.1200.12_1
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’s Supplement to
…
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.447706.1320.22
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.447706.106.0
2 pg
…to compel Defendant to Produce Documents
Subject to Improper Objections, filed February 26 , 2016, ECF No.
35, was granted in part and denied in part as set forth in open
court on March 17, 2016. See ECF Nos. 66, 98…
giuffre-maxwell
gov.uscourts.nysd.447706.153.0
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.447706.1198.6_2
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.447706.1328.8
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’s Motion to…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.4
23 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.447706.1320.11
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.447706.1256.6
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…