giuffre-maxwell
gov.uscourts.nysd.447706.185.4
10 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.363.4
11 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.5
11 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1074.0
18 pg
…unnamed victims, Jane Doe 3 and Jane Doe 4, moved
to join as petitioners in this action pursuant to Federal Rule of Civil Procedure 21. (DE 280).
Petitioners (Jane Doe 1 and Jane Doe 2) support the Rule 21 Motion. …
giuffre-maxwell
gov.uscourts.nysd.447706.1090.10_2
4 pg
…07433-RWS
v.
Ghislaine Maxwell,
Defendant.
______________________________/
NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF
PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN
FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2)(a)(ii), FILED UNDER SEAL
I…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.6
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
1320-9
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.592.0
5 pg
…DEFENDANT’S COUNTER-DESIGNATIONS TO PLAINTIFF’S
DEPOSITION DESIGNATIONS
Defendant Ghislaine Maxwell, through her attorneys and pursuant to Rule 32 of the
Federal Rules of Civil Procedures, hereby submits her counter-designations in accordance with
the Court’s October 3…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.3
10 pg
…by and
through undersigned counsel, to file this motion pursuant to Federal Rule of Civil Procedure 21
to join this action, on the condition that they not re-litigate any issues already litigated by Jane
Doe #1 and Jane Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1037.1
14 pg
…the Court more easily to manage and review any objections from Non-
Parties. The following procedure shall be used for each set of Sealed Items reviewed by the
Court:
a. The Court will notify the parties via minute order (“Notification”…
giuffre-maxwell
gov.uscourts.nysd.447706.1026.1
4 pg
…constitute a “motion” for purposes of this
Order and Protocol. The following procedure shall be used for each set of motions reviewed by
the Court:
a. The Court will notify the parties via minute order (“Notification”) of the set of…
giuffre-maxwell
gov.uscourts.nysd.447706.970.0
2 pg
…Page 2 of 2
The Honorable Loretta A. Preska
July 10, 2019
Page 2
concerns about the procedures discussed in the opinion, particularly as those
procedures apply to this action. Modification or vacatur of the opinion by the
panel or…
giuffre-maxwell
gov.uscourts.nysd.447706.1194.0_6
2 pg
…comfort in the fact that Ms. Maxwell
recognizes that she has the Federal Rules of Criminal Procedure and evidence at her disposal when
the appropriate time comes to fight this fight down the road.”). The Court’s reasoning was clear…
giuffre-maxwell
gov.uscourts.nysd.447706.1339.0
3 pg
… Case 1:15-cv-07433-LAP Document 1339 Filed 01/12/24 Page 2 of 3
to other categories of sensitive information set out in the Court’s
individual practices and Federal Rule of Civil Procedure 5.2.
Second…
giuffre-maxwell
gov.uscourts.nysd.447706.1262.1
2 pg
…Code (Title 28, U.S.C.) which pertain to the
jurisdiction of, and practice in, the United States District Courts;
b. The Federal Rules of Civil Procedure;
c. The Federal Rules of Criminal Procedur
giuffre-maxwell
gov.uscourts.nysd.447706.1226.0
4 pg
…release of Sealed Materials; (b) establishing a fixed schedule and procedure for both parties
and non-parties to promptly state their respective positions on the release of Sealed Materials,
including the opportunity to participate in an evidentiary hearing; and (c…
giuffre-maxwell
gov.uscourts.nysd.447706.1044.0
13 pg
…the Court more easily to manage and review any objections from Non-
Parties. The following procedure shall be used for each set of Sealed Items reviewed by the
Court:
a. The Court will notify the parties via minute order (“Notification”…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…Boyce Presidential Professor of Criminal Law and University
Distinguished Professor of Law at the S.J. Quinney College of Law, where I teach criminal
procedure, criminal, and crime victims’ rights.
1
Case 1:15-cv-07433-LAP Document 1330…
giuffre-maxwell
gov.uscourts.nysd.447706.941.0
6 pg
…it does not
authorize the Court to give litigants unfettered authority to decide what should or should not be
sealed. Neither do the ordinary procedures of the Southern District of New York. Pursuant to the
Electronic Case Filing Rules & Instructions…
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