giuffre-maxwell
gov.uscourts.nysd.447706.1269.0
1 pg
…No.: 15-cv-07433-LAP
GHISLAINE MAXWELL,
Defendant.
PROPOSED ORDER GRANTING THE MOTION TO WITHDRAW
SANFORD BOHRER AS COUNSEL FOR INTERVENORS
This matter having come before the Court by the filing of the Motion to Withdraw Sanford
Bohrer as Counsel…
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.447706.1184.0
1 pg
…Dershowitz, Case No.: 19-cv-03377-LAP
Your Honor:
Professor Alan Dershowitz and Ms. Virginia Giuffre hereby jointly request that the Court grant
them until January 5, 2021 to respond to the December 23, 2020 letter filed on behalf of…
giuffre-maxwell
gov.uscourts.nysd.447706.1183.0_3_1
1 pg
…Dershowitz, Case No.: 19-cv-03377-LAP
Your Honor:
Professor Alan Dershowitz and Ms. Virginia Giuffre hereby jointly request that the Court grant
them until January 5, 2021 to respond to the December 23, 2020 letter filed on behalf of…
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.447706.1355.0
1 pg
…however, we would
want to be afforded the opportunity to file an opposition to the Motion before it is decided.
Accordingly, we respectfully request that the Court grant J Doe 12 permission, if
necessary, to file an opposition to 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.447706.204.0
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.447706.27.1
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.447706.140.0
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.447706.24.0
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.447706.739.0
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.447706.1328.29
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…
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