giuffre-maxwell
gov.uscourts.nysd.447706.928.0
11 pg
…Modify the Protective Order for the reasons set forth below. The Proposed
Intervenors are two non-parties, Jeffrey Epstein and Leslie Groff (“Epstein Defendants”).
PRELIMINARY STATEMENT
PROCEDURAL HISTORY
On March 18, 2016, this Court entered a Protective Order (DE 62…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…Confession
3€>!5.171 (15) Identity of 911 reports are confidential for period of 60 days after
seHvice
1 'I 9.071 (2)(d) Surveillance t niques, procedures, an (2)(h)(1) Identity of victim of sexual battery, lewd and…
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
gov.uscourts.nysd.447706.5.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.3.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.8.0
2 pg
…Civ.
P. 12 (a)(2) or (3) — you must serve on the plaintiff an answer to the attached complaint or a motion under Rule 12 of
the Federal Rules of Civil Procedure. The answer or motion must be served on…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro Hac…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.43
8 pg
…Epstein's
18 described? 18 house or where?
19 A. Yes, it was normal procedure. 19 A. Mrs. Maxwell took him to England to
20 Q. Rodriguez stated Epstein did not want to 20 introduce him to the royalty.
21…
giuffre-maxwell
1320-30
27 pg
…Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1320-30 Filed Inc. Page 5 of 27
01/03/24
1 Pursuant to Notice and the Federal Rules
2 of Civil Procedure, the VIDEOTAPED …
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…PROPERTY [ ) 699 ADMINISTRATIVE
[ ] 441 VOTING IMMIGRATION
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.30
27 pg
…Case 1:15-cv-07433-LAP Court Reporting
Document & Video,
1320-30 Filed Inc. Page 5 of 27
01/03/24
1 Pursuant to Notice and the Federal Rules
2 of Civil Procedure, the VIDEOTAPED …
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.3
16 pg
…Pilots Larry Visoski ✓ Jane Doe 2
Dave Rodgers
Larry Morrison
Mr Epstein's planes Jet Aviation (561) 233-7241
Procedur…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…and the question was properly objected to.
H. Objections to Questions 9, 10, and 11.
17
Federal Rule of Civil Procedure 26(b)(1) provides, in relevant part, that "[p]arties may
obtain discovery regarding any matter, not privileged…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.26
27 pg
…the
Court’s Order as it is not tied to a person, location, or key event associated with this case.
Federal Rule of Civil Procedure 26(b)(1) provides, in relevant part, that "[p]arties may
obtain discovery regarding any…
giuffre-maxwell
gov.uscourts.nysd.447706.55.21
69 pg
…No, sir. 19 phones.
20 Q. Anything else you can remember that you 20 Q. Was there a procedure or protocol for
21 were told specifically regarding his preferences? 21 answering the phones?
22 A. He likes Columbian coffee, that…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…the needs of the case.
Such requests create a heavy burden on Ms. Giuffre that outweighs any benefit. Such discovery
is prohibited by the Federal Rules of Civil Procedure, particularly under the 2015 amendments to
Rule 26(b)(1), Fed…
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