giuffre-maxwell
gov.uscourts.nysd.447706.1125.0_2
5 pg
…privacy, and (3)
requesting excerpts of sealed materials that mention them for their
review (the “September 25 Email”).
The parties dispute the procedural import of the September 25
Email under the Protocol governing the unsealing of documents in
this action…
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.447706.659.0
7 pg
…INSTRUCTION
Ms. Giuffre hereby files a Renewed Motion to Compel Data from Defendant’s
Undisclosed Email Accounts and for an Adverse Inference Jury Instruction, and states as
follows.
I. SIGNIFICANT PROCEDURAL HISTORY
On October 14, 2016, Ms. Giuffre filed a…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…Defendant. West Headnotes (37)
Civil Action No. 14–30211–MGM | Signed October 9,
2015 [1]
Federal Courts
Substance or procedur
giuffre-maxwell
gov.uscourts.nysd.447706.1289.0
3 pg
…at 1.1 Doe 171’s motion is procedurally and
substantively deficient and should be denied outright.
While Doe 171 filed her letter as a “motion to seal,” it is instead clearly a motion for
reconsideration governed by Local Civil…
giuffre-maxwell
gov.uscourts.nysd.447706.1058.1
3 pg
…his case and in Maxwell allowing him access to all discovery materials and pleadings in Maxwell.
Of course, if the Court prefers a different procedural route to accomplish what he requests, then
Professor Dershowitz will follow the Court’s directive.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1305.0
4 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1126.0
3 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1304.0
3 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.1025.0
17 pg
…for various reasons, most of which will be apparent,
e.g., the protocol did not address various substantive and procedural issues, it did not
account for the Court’s rulings and comments at the January 16 status conference, and,
in…
giuffre-maxwell
gov.uscourts.nysd.447706.422.0
8 pg
…Decl.
Ex. B. The parties have been unable to reach a resolution without the need for Court
intervention.
I. PROCEDURAL HISTORY
On February 12, 2016 Ms. Maxwell served her First Set of Discovery Requests on
Plaintiff. Request Number 19…
giuffre-maxwell
gov.uscourts.nysd.447706.1303.0
3 pg
…after January 1, 2007, is permitted and is governed by Federal Rule of Appellate
Procedure 32.1 and this Court’s Local Rule 32.1.1. When citing a summary order in a
document filed with this Court, a party…
giuffre-maxwell
gov.uscourts.nysd.447706.375.0
4 pg
…was filed. Defendant, wanting the
Court to ignore her further misconduct, again, wrongly moves to strike.
1. The Motion to Strike Should be Denied As Improper
The instant motion is procedurally improper, as Rule 12(f), Fed. R. Civ. P…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.3
21 pg
…entitled to present those changed circumstances
-
to the Court.
In an effort to deflect attention from the merits of attorney-client issues, Defendant raises
the procedural argument that somehow Ms. Giuffre has failed to provide an appropriate
certificate of conferral…
giuffre-maxwell
gov.uscourts.nysd.447706.1118.0
21 pg
…in a private suit, the proper procedure is to seek permissive intervention under
2
Case 1:15-cv-07433-LAP Document 1118 Filed 09/16/20 Page 4 of 21
Rule 24(b).” Daniels v. City of New York…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…interests).
B. Federal Law Rather than New York Law Controls the Evidentiary Issue of
Whether Can Be Called as Witnesses.
9
“[F]ederal courts sitting in diversity apply state substantive law and federal procedural
law.” U.S.…
giuffre-maxwell
gov.uscourts.nysd.447706.1287.0
2 pg
…7433 (LAP)
VIRGINIA L. GIUFFRE,
Plaintiff,
v.
GHISLAINE MAXWELL,
Defendant.
/
NOTICE OF REDACTION REQUEST – TRANSCRIPT
In accordance with this Court’s forms and procedures, undersigned counsel acknowledges
that redactions o…
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.447706.1110.0
2 pg
…Preska, for an order pursuant to Federal Rule of Civil Procedure
24 granting the USVI’s motion to intervene and for confidential access to judicial records and
discovery documents. The grounds for this motion are set forth in the accompanying…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.12
7 pg
…24 Page 2 of 7
Defendant Ghislaine Maxwell (“Ms. Maxwell”), pursuant to Federal Rule of Civil
Procedure 53, files this Motion to Appoint a Special Master to Preside over the Third Deposition
of Defendant Ghislaine Maxwell, and states as follows:
…
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