giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…2016 Letter Motion to Compel Defendant to Sit for Her
Deposition (DE 63) - Granted (DE 106).
Plaintiff’s Motion to Compel Documents Subject to Improper Claim of Privilege (DE
33) - Granted in Part (DE 73).
Plaintiff’s Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…1
On Friday, September 23, 2016, counsel for Ms. Giuffre sent a letter to Defendant inquiring about the undisclosed
account. As of the date of this motion, Defendant has made no response.
2
A. The Account
Ms. Giuffre has…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…2016 Letter Motion to Compel Defendant to Sit for Her
Deposition (DE 63) - Granted (DE 106).
Plaintiff’s Motion to Compel Documents Subject to Improper Claim of Privilege (DE
33) - Granted in Part (DE 73).
Plaintiff’s Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.33
24 pg
…a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April 25, 2016, outlining the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…2016 Letter Motion to Compel Defendant to Sit for Her
Deposition (DE 63) - Granted (DE 106).
x Plaintiff’s Motion to Compel Documents Subject to Improper Claim of Privilege (DE
33) - Granted in Part (DE 73).
x Plaintiff’s Motion…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.1_2
24 pg
…a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April 25, 2016, outlining the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.34
4 pg
…26, 2016,
and designated by Plaintiff as Confidential under the Protective Order.
13. Attached as Exhibit L is a true and correct copy of a letter from Laura A.
Menninger to Sigrid McCawley dated April 25, 2016 concerning discovery.
14…
giuffre-maxwell
1320-33
24 pg
…a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April 25, 2016, outlining the…
giuffre-maxwell
1320-34
4 pg
…26, 2016,
and designated by Plaintiff as Confidential under the Protective Order.
13. Attached as Exhibit L is a true and correct copy of a letter from Laura A.
Menninger to Sigrid McCawley dated April 25, 2016 concerning discovery.
14…
giuffre-maxwell
gov.uscourts.nysd.447706.231.0
23 pg
…a), stating
as follows:
CERTIFICATE OF CONFERRAL
The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an
attempt to obtain records and interrogatory responses Ordered by the Court, including by letter
dated April 25, 2016, outlining the…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…the search terms are not to be treated as case-sensitive, meaning that the terms
should be searched according to their letters, regardless of whether they are represented
in the list as containing upper case or lower case letters.
Should…
giuffre-maxwell
gov.uscourts.nysd.447706.1068.0
31 pg
…172, 199,
and 230 (or “the first five motions”), Maxwell has illustrated the very problem that Plaintiff pointed
out in the Original Parties’ April 30, 2020 joint letter to the Court. See ECF No. 1052. Because
only Doe 1 and…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.22
22 pg
…Depose Ross Gow
(pending); DE 330 and 331, Application for Letters Rogatory (application granted and letter
issued by the Court on August 11, 2016 (DE 358)).
Against the backdrop of these repeated evasion efforts, Defendant’s sale of $15 million…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…7, 1016, Email to Sarah Kellen; July 11, 2016,
2
Case 1:15-cv-07433-LAP Document 308 Filed 07/25/16 Page 3 of 7
Letters to Sarah Kellen. Ms. Giuffre also, in an abundance of caution, provided…
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