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gov.uscourts.nysd.447706.22.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.22.0 14 pg
D6 P17 V11 D5 P18

…Maxwell referenced four glaring examples of Plaintiff’s so-called “narrowly tailored” discovery requests. The rest are no more “narrowly tailored”; other examples include:  All documents identifying passengers, manifests, or flight plans for any helicopter or plane ever owned…

gov.uscourts.nysd.447706.1325.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.19 20 pg
P17 V14 P22 V11 D5

… Identify all flights you have taken on aircraft on which Ms. Giuffre was also a passenger. ANSWER: Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly burdensome and calls for information that is…

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