gov.uscourts.nysd.447706.18.0.pdf PDF
…L. GIUFFRE, PLAINTIFF, V. 15-cv-07433-RWS GHISLAINE MAXWELL, DEFENDANT. --------------------------------------------------X MEMORANDUM OF LAW IN SUPPORT OF MOTION FOR A STAY OF DISCOVERY PENDING DE…
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gov.uscourts.nysd.447706.91.0.pdf PDF
…Compel Defendant Ghislaine Maxwell, through counsel, hereby requests that the Court permit the filing of a reply memorandum in excess of the 10 pages permitted pursuant to this Court’s Practice Standard 2D. As grounds, she further avers as follows…
gov.uscourts.nysd.447706.1169.0_1.pdf PDF
…NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes with respect to Defendant’s Reply Memorandum of Law in Support of Objections to Unsealing Materials Related to Docket Entries 231, 279, 315…
gov.uscourts.nysd.447706.1023.0.pdf PDF
…Ghislaine Maxwell, Defendant. NOTICE OF MOTION FOR RECONSIDERATION PLEASE TAKE NOTICE, upon the accompanying Memorandum in Support, pursuant to Local Rule 6.3 of the Local Rules of the United States District Court for the Southern District of New York…
gov.uscourts.nysd.447706.1202.0_2.pdf PDF
…and January 26, 2021 (ECF No. 1193), Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to Docket Entries 231, 279, 315…
gov.uscourts.nysd.447706.377.0.pdf PDF
…by and through her undersigned counsel, hereby request that the Court permit the filing of a response memorandum in excess of the 25 pages permitted pursuant to this Court’s Practice Standard 2D, and states as follows. Defendant filed an…
gov.uscourts.nysd.447706.14.0.pdf PDF
…accompanying Declaration of Laura A. Menninger, dated November 30, 2015, and the exhibits thereto and the accompanying Memorandum of Law, dated November 30, 2015, any other matters of which the Court may take judicial notice, and upon all prior pleadings…
gov.uscourts.nysd.447706.221.0.pdf PDF
…of Gregory L. Poe dated June 16, 2016, the exhibits attached to the declaration, the accompanying memorandum of law, and all pleadings and proceedings herein, the undersigned will move this Court, before the Honorable Robert W. Sweet, United States District…
gov.uscourts.nysd.447706.218.0.pdf PDF
…Civ. 7433-RWS : GHISLAINE MAXWELL, : ECF CASE : Defendant. : X MEMORANDUM OF LAW IN SUPPORT OF NON-PARTY SHARON CHURCHER’S MOTION T…
gov.uscourts.nysd.447706.534.0.pdf PDF
…New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION IN LIMINE AND INCORPORATED MEMORANDUM OF …
gov.uscourts.nysd.447706.768.0.pdf PDF
…respectfully submits this memorandum of law in response and opposition to Defendant’s Motion to Prohibit Questioning Regarding Defendant’s Adult Consensual Activities. PRELIMINARY STATEMENT 1 Case 1:15-cv-07433-RWS Document 768 Filed 03/22/17 Page 5…
gov.uscourts.nysd.447706.1325.1.pdf PDF
…created5 x Notes, transcriptions, tape recordings, and memorandum from her interviews with Plaintiff, including her week long interviews in Australia;6 x Churcher’s communications with law enforcement or the FBI concerning Plaintiff;7 5 Plaintiff contends that she gave…
gov.uscourts.nysd.447706.1320.31.pdf PDF
…another. 2. "Con-espondence" or "communication'' shall mean all ·written or verbal communicalions, by any and all methods_, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or received: and, includes…
gov.uscourts.nysd.447706.17.1.pdf PDF
… “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or 1 …
gov.uscourts.nysd.447706.370.1.pdf PDF
… “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or 1 Case 1:15-cv…
gov.uscourts.nysd.447706.1218.9.pdf PDF
…Giuffre and Ms. Churcher were alleging to be the nature and content of their relationship. Among other things, the Reply Memorandum of Law submitted on behalf of Ms. Churcher asserts the following: Churcher makes no suggestion that [Ms. Giuffre] had…
gov.uscourts.nysd.447706.1219.29.pdf PDF
…behalf of another. 4. “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or received; and…
gov.uscourts.nysd.447706.1206.0_1.pdf PDF
…L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, 15-cv-07433-LAP Defendant. --------------------------------------------------X GHISLAINE MAXWELL’S NOTICE OF FILING PLEASE TAKE NOTICE THAT the accompanying Notices, <…
gov.uscourts.nysd.447706.1020.0.pdf PDF
…Ms. Maxwell and the non-parties. The volume of Sealed Materials is substantial. The Sealed Materials contain motions, responses, replies, surreplies, sur-surreplies, memoranda, correspondence, declarations, exhibits, notices, and orders. Depending whether the materials were filed under seal, each motion…
gov.uscourts.nysd.447706.1200.13_1.pdf PDF
…calendars, blog posts (whether published or not), notes (handwritten or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name.” Plaintiff is asking defendant…
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