giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
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.447706.1320.10
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
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
1320-10
28 pg
… Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S NON-REDACTED MOTION TO EXCEED PRESUMPTIVE TEN
DEPOSITION LIMIT IN FEDERAL RULE CIVIL PROCEDURE 30(A)(2)(a)(ii)
Sigrid McCawley (Pro H…
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.447706.363.0
18 pg
…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…
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.447706.1325.3
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.447706.1328.22
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.447706.1328.21
19 pg
…e) Confession C ormants
C 3E>t,.171 (15) Identity of 911 reports are confidential for period of 60 days after
service
C 11 ~W71 (2)(d) Surveillance t niques, procedure…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
… Ms. Maxwell objects to the Interrogatories to the extent they attempt to impose
any requirement or discovery obligation greater than or different from those under the Federal
Rules of Civil Procedure, the local rules of this Court or any Orders…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.25
10 pg
…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…me.
8 MR. CASSELL: Your Honor, maybe Mr. Edwards could
9 briefly explain Florida procedure. The case has been
10 dismissed, but it does not require a Court's signature.
11 Mr. Edwards can elaborate more fully on that.
12 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.10
23 pg
…8 already .
9 MR. BOIES : Exactly the procedure
10 that I have proposed from the beginning .
11 If you think a question is out of
12 bounds , instruct not to answer and we
13 will then let the judge decide…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…I apologize, disclosure pursuant to Federal
18 Rule of Civil Procedure 26.
19 This is a document that was entered in your
20 lawsuit against Ghislaine Maxwell in the Southern
21 District of New York. Have you ever seen this…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…it would become standard operating procedure,
19 and the resulting wholesale exposure of press files to
20 litigants' scrutiny would burden the press with heavy costs of
21 subpoena compliance and could otherwise impair its ability to
22 perform its…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…these
documents are confidential and should be kept under seal. Rule 26(c) of the Federal Rules of
Civil Procedure permits a district court to “make any order which justice requires to protect a
party or person from annoyance, embarrassment…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.16
30 pg
…hearing, this Court denied that motion with
leave to refile (DE 106).
14
Defendant repeatedly attempts to conflate the required disclosures under Federal Rule of Civil
Procedure 26(a) and the disclosures ordered by this Court on April 21, 2016…
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