giuffre-maxwell
gov.uscourts.nysd.447706.110.0
7 pg
…Court for the Southern District of New York (“SDNY”), titled, M10-
468- In re Pilot Project Regarding Case Management Techniques for Complex Civil Cases in
the Southern District of New York. Pl’s Motion at 9. On the other hand…
giuffre-maxwell
gov.uscourts.nysd.447706.96.0
15 pg
…2015) ....................................9, 10
Statutes
Federal Rule of Civil Procedure 26 .................................................................................................8
Other
In re: Pilot Project Regarding Case Management Techniques for Complex
Civil Cases in the Southern District of New York, M10-468 …
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…Standing Order M10-468, In re: Pilot Project Regarding Case Management
Techniques for Complex Civil Cases in the Southern District of New York, requires a Joint E-
1
Case 1:15-cv-07433-LAP Document 121 Filed 04/25…
giuffre-maxwell
gov.uscourts.nysd.447706.13.0
1 pg
…order to the defendant(s) on or before the completion of discovery. The
parties are advised that this Court is participating in a Pilot Program for initial
discovery protocols for employment cases alleging adverse action. See www.fjc.gov.
3…
giuffre-maxwell
gov.uscourts.nysd.447706.45.0
17 pg
…2
Meeker v. Life Care Ctrs. of Am., No. 14-CV-02101-WYD- NYW, 2015 WL 4400533 .............. 4
Parsons v. Jefferson-Pilot Corp., 141 F.R.D. 408, 412 (M.D.N.C. 1992) ..................................... 5
Piacenti v. Gen. Motors Corp…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Id. But
Plaintiff has asserted that she spent time with President Clinton on the island of Little St. James,
US Virgin Islands and that she flew there with the President in a helicopter piloted by Ms.
-
Maxwell. In one article…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
Epstein household employees), as well as Dana Burns and Emmy Taylor…
giuffre-maxwell
gov.uscourts.nysd.447706.1343.1
23 pg
…22 of 23
Page 410
1 G Maxwell - Confidential
2 Q. Were there other flights that you
3 recall flying on with Jeffrey Epstein that
4 were on flights that -- where Dave Rogers was
5 not the pilot?
6 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.11_3
23 pg
…20 Page 22 of 23
Page 410
1 G Maxwell - Confidential
2 Q. Were there other flights that you
3 recall flying on with Jeffrey Epstein that
4 were on flights that -- where was
5 not the pilot?
6 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…1570 and 1589 (Epstein’s pilot testified that the
passenger listed on his flight log bearing the initials – GM – was in fact Ghislaine Maxwell and
Rodgers was the pilot on at least 23 of the flights in which Defendant flew…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
-
Epstein household employees), as well as Jane Doe 2 and Emmy…
giuffre-maxwell
1320-20
11 pg
…Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
-
Epstein household employees), as well as Jane Doe 2 and Emmy…
giuffre-maxwell
1320-28
32 pg
…Id. But
Plaintiff has asserted that she spent time with President Clinton on the island of Little St. James,
US Virgin Islands and that she flew there with the President in a helicopter piloted by Ms.
-
Maxwell. In one article…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…Johanna Sjoberg
(a former Epstein employee), Juan Alessi (a former Epstein employee), and David Rodgers4
(former Epstein Pilot). She further seeks to depose Maria Alessi and Jo Fontanella (former
Epstein household employees), as well as Dana Burns and Emmy Taylor…
giuffre-maxwell
gov.uscourts.nysd.447706.42.0
7 pg
…665 (D. Kan. 1999) (holding that challenged discovery request was facially
overbroad due to its use of the “omnibus phrase ‘relating to’”); Parsons v. Jefferson-Pilot
Corp., 141 F.R.D. 408, 412 (M.D.N.C. 1992) (“[b]road…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
….." Id. But
Plaintiff has asse1ted that she spent time with on the island of Little St. James,
US Virgin Islands and that she flew there with the- - in a helicopter piloted by Ms.
Maxwell. In one article, authored by Sharon…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.3
16 pg
…2300 Public Records Request No.: 16-268
Case 1:15-cv-07433-LAP Document 1327-3 Filed 01/05/24 Page 8 of 16
TRAVEL
Pilots Larry Visoski ✓ Jane Doe 2
Dave Ro…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…addresses (only of their counsel) as to just two, Jeffrey Epstein and Alan
Dershowitz. Plaintiff then also listed categories of witnesses such as “all other then-minor girls,
whose identities Plaintiff will attempt to determine” and “all pilots, chauffeurs, chefs…
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