Found 43 results for “months” in 153ms

gov.uscourts.nysd.447706.1330.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.17 12 pg

…states as follows: INTRODUCTION Plaintiff comes to this Court – for the third time – seeking to reopen the deposition of Ms. Maxwell based on the production of two innocuous documents which she received more than two months ago on August 16…

gov.uscourts.nysd.447706.130.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.130.0 5 pg

…Plaintiff, forthwith, to deliver any “materials” to the Defendant for the following reasons: For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her claim that there is an ongoing and active criminal investigation in which Ms…

gov.uscourts.nysd.447706.443.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.443.0 4 pg

…Plaintiff, Ms. Giuffre, by and through her undersigned counsel hereby gives this Court notice of a related action, and states as follows. For many months, Ms. Giuffre has attempted to serve process on Defendant’s press agent, Ross Gow, who…

gov.uscourts.nysd.447706.363.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.9 5 pg

…in Judge Freeh’s professional opinion, “The totality of the evidence found during the investigation refutes the allegations made against Professor Dershowitz.” STATEMENT OF LOUIS J. FREEH Over the past several months, an independent investigation was conducted, under my supervision…

gov.uscourts.nysd.447706.34.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.34.2 3 pg

…opportunities. • See who you know in common • Get introduced • Contact Ross directly Experience Owner, Managing Partner ACUITY Reputation January 2010 – Present (6 years 2 months) ACUITY advises Governments, Corporates and UHNWIs on reputational issues Skills Public Relations Marketing …

gov.uscourts.nysd.447706.1198.13_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.13_1 19 pg

…this claim. As she now admits, Plaintiff only began to request her own medical records on April 5, 2016 – 15 months after the supposed defamation, 8 months after filing suit, 8 weeks after the defense requested the records, 2 weeks…

gov.uscourts.nysd.447706.1227.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1227.0 2 pg

…1226 at 2, 3. As Plaintiff clearly laid out in a letter submitted to the Court nine months ago, because the Court is currently proceeding through the unsealing process on a Doe-by-Doe basis, the Original Parties’ understanding is…

gov.uscourts.nysd.447706.1295.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.11 19 pg

…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff then asked this Court to re-open discovery for the deposition of Ms. Ransome…

gov.uscourts.nysd.447706.269.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.269.0 19 pg

…this claim. As she now admits, Plaintiff only began to request her own medical records on April 5, 2016 – 15 months after the supposed defamation, 8 months after filing suit, 8 weeks after the defense requested the records, 2 weeks…

gov.uscourts.nysd.447706.751.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.751.9 3 pg

…deal that allowed Epstein to avoid much more serious federal charges and potentially longer prison time. Epstein served 13 months of an 18-month sentence after pleading guilty to a single charge of soliciting prostitution before being released in 2009…

gov.uscourts.nysd.447706.1228.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1228.0 4 pg

…Similarly, the replies of the non-parties would have been submitted at least six months ago and thus the issues would have been at least fully briefed. But, because of the modification requested by the original parties after the Protocol…

gov.uscourts.nysd.447706.1331.30.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.30 19 pg

…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff then asked this Court to re-open discovery for the deposition of Ms. Ransome…

gov.uscourts.nysd.447706.1008.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1008.0 5 pg

…Act of 1990 requires the Administrative Office of the United States Courts to prepare a semiannual report summarizing judicial inaction, including motions pending more than six months and civil cases pending more than three years. See 28 U.S.C…

gov.uscourts.nysd.447706.1250.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1250.0 7 pg

…among others, that: (1) the government did not move to seal the state-court records until they had already been publicly available on the federal docket for eight months; (2) the government made a conclusory claim that mere redactions were…

gov.uscourts.nysd.447706.587.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.587.0_2 10 pg

…a motion for sanctions. 14 We have a separate trial in this case in March and they waited 15 until nine months after they first raised the issue to bring it 16 to the Court's attention with this motion…

gov.uscourts.nysd.447706.1042.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1042.0 2 pg

…response time for any Non-party objections, as well as for responses to objections and replies. This will prolong the process into a months-long endeavor. The Second Circuit’s ruling in this matter was issued on July 2, 2019…

gov.uscourts.nysd.447706.276.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.276.0_1 35 pg

…Churcher has continued to cover this story as 9 a reporter, has published stories, including just I think two 10 months ago, often using "Virginia" or her so-called agents as 11 sources, of course most prominently in early 2015…

gov.uscourts.nysd.447706.121.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.121.0 10 pg

…expended considerable sums of money and considerable time to ensure Ms. Giuffre’s compliance with her discovery obligations. (DE 96 at 7.) Fact discovery closes in less than two months, and Defendant has yet to disclose information about what was…

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