giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…2016 that Ms. Maxwell must sit for a second deposition on
eight topics all “relating to [her] own sexual activity” and “her knowledge of the sexual activity
of others.” (DE 316-6 at 10) Judge Sweet overruled Ms. Maxwell’s…
giuffre-maxwell
gov.uscourts.nysd.447706.148.0
9 pg
…When Ms. Maxwell demonstrated that the “investigative privilege” did not exist,
Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was
overruled by the Court on April 21, 2016.
The Court Ordered:
“The criminal investigation. Any materials…
giuffre-maxwell
gov.uscourts.nysd.447706.1279.0
2 pg
…giving Doe 171 ample notice to decide on what she wanted
to do in the event the Court overruled her objection.
Doe 171 has had ample time to appeal in a non-urgent basis and she has not done so…
giuffre-maxwell
gov.uscourts.nysd.447706.35.0
31 pg
…relevant. Ms. Giuffre respectfully requests that this Court
direct Maxwell to produce all responsive documents for the time period from 1999 to the
present.6
Defendant Maxwell has also asserted fundamentally improper general objections which
should be overruled. Am. Rock…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
giuffre-maxwell
gov.uscourts.nysd.447706.1062.0
7 pg
…85.
B. Dershowitz’s Present, Expanded Second (or Third) Bite at the Apple and
Giuffre’s Acquiescence to the Same
With his objections to the protocol overruled in Maxwell, and having already failed to
circumvent it once in Dershowitz, Dershowitz…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.4
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.12
223 pg
…MCCAWLEY: I can make my record, and my
16 record is she's not going to be speaking with
17 respect to individuals' names that are named in
18 generalities in this document.
19 SPECIAL MASTER: Objection overruled. You
20…
giuffre-maxwell
gov.uscourts.nysd.447706.43.0
15 pg
…generalized
objections that discovery requests are vague, overly broad, or unduly burdensome are not
acceptable, and will be overruled.”). Therefore, this Court should require Defendant to produce
the documents she admits to withholding.
3. This Court Should Grant Plaintiff’s…
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…withholding any documents based on “copyright” and
“proprietary” objections. In fact, she did withhold those documents – until this
Court overruled her objection on March 17th. (Transcript at 13-17). She then
provided thousands of pages of supposedly “copyright protected” and…
giuffre-maxwell
gov.uscourts.nysd.447706.185.8
24 pg
…privilege in these circumstances would result in nothing more than the
concealment of the truth. Plaintiffs’ objections on the basis of the attorney-client privilege
should be overruled.
2. Plaintiffs Have Waived Their Right To Rely On The Work Product…
giuffre-maxwell
gov.uscourts.nysd.447706.354.0
40 pg
…2016).
Plaintiff objected to this interrogatory on the ground it requested pre-1999 medical
information in “violat[ion]” of the Court’s ruling. The objection should be overruled. The issue
4
Plaintiff’s voluminous arguments and argumentative citations to case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.36
2 pg
…Dershowitz Regarding Meetings with
David Boies" to Defendant Alan M. Dershowitz's Motion in Limine to Overrule Objections As to
Application of Settlement Rules, Filing # 35429605 E-Filed 12111/2015 at 10:08:04 a.m.
Having reviewed the record…
giuffre-maxwell
gov.uscourts.nysd.447706.55.10
10 pg
…same
www.phippsreporting.com
(888)811-3408
Case 1:15-cv-07433-LAP Document 55-10 Filed 03/14/16 Page 10 of 10
528
1 instruction.
2 SPECIAL MASTER POZZUOLI: And I'm going to
3 over…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…sanctions against Defendant, Alan M. Dershowitz in connection to his filing the
Motion in Limine to Overrrule Objections As to Application of Settlement Rules, Filing#
35429605 E-filed 12/11 /2015 at 10:08:04 a.m., and to strike…
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…seizure—within the meaning of the fourth
amendment.” Boyd v United States, 116 U.S. 616, 634–35 (1886), overruling in part on other
grounds as recognized in Fisher v. United States, 425 U.S. 391, 407–08 (1976).
Finally…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…the
hearing of the same day, compelling Defendant to produce documents. Despite this Court
overruling numerous objections brought by Defendant, including her objection on the self-serving
selection of dates from which to produce documents, Defendant has not yet turned…