…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…
…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…
…SERVICE OF RlTT~E 45 SUBPOENA TO PRODUCE DOCUMENTS, INFORMAT[ON, OR OBJECTS OR TO PERMIT INSPECTION OF PRE.MISES UPO)l JEAN LUC BRUNEL PLEASE TAKE NOTICE THAT, pursuantto Rule 45 oftbc .Federal Rules of Civil Procedure, Plaintiff, Virginia Giuffre…
…X ............................................... Virginia L. Giuffre, Plaintiff, v. 15-cv-07433-RWS Ghislaine Maxwell, Defendant. --------------------------------------…
…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…
…DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA GIUFFRE’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO COMPEL PLAINTIFF TO DISCLOSE PURSUANT TO FED. RULE CIV. PROCEDURE 26(a)(1) I, Sigrid S. McCawley, declare that the…
…by and through her undersigned counsel, hereby propounds Plaintiff’s First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the…
…by and through her undersigned counsel, hereby propounds Plaintiff’s Second Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the…
…Motion to Stay Discovery during the pendency of her Motion to Dismiss. LEGAL STANDARD Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to stay discovery “for good cause shown.” Spencer Trask Software and Info…
…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…
…15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ 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…
…career. I am personally familiar with the facts set forth in this declaration. 2. I submit this Declaration in support of my motion for permissive intervention under Federal Rule of Civil Procedure 24(b), and to unseal certain judicial documents…
…Motion. Specifically, this Court held: Federal Rule of Civil Procedure 26(f)(3)(C) requires the parties to state their views and proposals as to preservation of electronically stored information (“ESI”) and the form of the production of ESI. Fed…
…Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e…
…Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e…
…Whilst any attachments may have been checked for viruses, you should rely on your own virus checker and procedures. No responsibility is accepted by ACUITY Reputation Limited for loss or damage arising from the receipt or use of this e…
…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…
…Cf. Fed. R. Civ. P. 1 (rules of procedure should be construed to secure the “just, speedy, and inexpensive determination of every action”). II. ARGUMENT A. Plaintiff Has Demonstrated Good Cause for an Extension of Time, and the Southern District…
…Pursuant to that Rule, parties have an obligation to be transparent about their electronically stored information (ESI) preservation, collection, and production procedures, and an obligation to attempt to mutually agree to such procedures. See Stinson v. City of New York…
…served on Apple, with whom she maintains an email account. The Court’s authority to issue such a protective order is well established. Federal Rule of Civil Procedure 26(c)(1)(A) & (D) states that “[a] party . . . may move for…
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