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.447706.343.0
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.447706.1355.0
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.447706.1218.37
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.447706.204.0
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.447706.27.1
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…
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.447706.1090.10_2
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…
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