giuffre-maxwell
gov.uscourts.nysd.447706.363.6
15 pg
…NO. 3
Non-party Jane Doe 3, by and through undersigned counsel and pursuant to Florida Rules
of Civil Procedure 1.410(c)(1)1, hereby moves for an order quashing the subpoena duces tecum
served on her by Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1302.0
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.447706.1305.0
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.447706.1328.5
45 pg
…cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S RESPONSES AND OBJECTIONS TO DEFENDANT’S SECOND
REQUEST FOR PRODUCTION AND DEFENDANT’S INTERROGATORIES,
PLAINTIFF’S ANSWERS TO DEFENDANT’S REQUESTS FOR ADMISSION
Pursuant to Federal Rules of Civil Procedure 26…
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:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1266.0
4 pg
…Doe.
(Dkt. no. 1264.)
It is well-settled that intervention pursuant to Rule 24(b)
is the proper procedure for a third party to seek to modify a
protective order in a private suit. See United States v. Alex
Brown…
giuffre-maxwell
gov.uscourts.nysd.447706.308.0
7 pg
…ASSOCIATED SANCTIONS
Petitioner, Virginia Giuffre, pursuant to Rule 45(g) of the Federal Rules of Civil
Procedure and Local Rule 83.6, by and through her undersigned counsel, respectfully moves this
Court to issue an order finding of civil contempt…
giuffre-maxwell
gov.uscourts.nysd.447706.71.6
19 pg
…X
...............................................
Virginia L. Giuffre,
Plaintiff,
v. 15-cv-07433-RWS
Ghislaine Maxwell,
Defendant.
--------------------------------------…
giuffre-maxwell
gov.uscourts.nysd.447706.1161.0_1
17 pg
…States District Judge:
The Government of the United States Virgin Islands (the
“USVI”) has moved (1) to intervene in the above-captioned action
pursuant to Rule 24 of the Federal Rules of Civil Procedure and
(2) should intervention be permitted…
giuffre-maxwell
gov.uscourts.nysd.447706.364.0
32 pg
…5000
TABLE OF CONTENTS
PAGE NO.
TABLE OF AUTHORITIES ...................................................................................................... iii-v
PRELIMINA…
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.447706.1331.16
10 pg
…A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable
Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are “unavailable witnesses”
whose testimony can be presented by deposition at trial under Rule 34 of the Federal Rules of
Civil Procedure…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…Motion for
Sanctions (“Sur-Reply”), stating as follows:
INTRODUCTION
Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the
requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has
“disclosed…
giuffre-maxwell
gov.uscourts.nysd.447706.540.0
3 pg
…the
Honorable Robert W. Sweet, for an order pursuant to Federal Rule of Civil Procedure 56 and
Local Civil Rule 56.1, granting Defendant’s motion for summary judgment and dismissing the
Complaint filed on September 21, 2015 in its…
giuffre-maxwell
gov.uscourts.nysd.447706.149.0
9 pg
…Deposition Questions Filed Under Seal (Doc. # 143 ) (“Motion” ).
Ms. Maxwell, pursuant to Rule 30(d)(3) of the Federal Rules of Civil Procedure, moves to
prohibit Plaintiff from asking her questions about any adult, In support of her
requests, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.29_1
16 pg
…Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S SUPPLEMENTAL RESONSES TO
DEFENDANT’S INTERROGATORIES 12 and 13
Pursua…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…interrogatories,
responses to requests for admission, deposition testimony, and other
information disclosed pursuant to the disclosure or discovery duties created by
the Federal Rules of Civil Procedure.
2. As used in this Protective Order, “document” is defined as provided in…
giuffre-maxwell
gov.uscourts.nysd.447706.13.0
1 pg
…1vr{_~~tQJ:Ileys, having appeared before this Court at
a pretrial conference on ~ ~ , pursuant to Rule 16 of the Federal
Rules of Civil Procedure, pursuant to ~~~~·~~~~~~~~~~~
I'l' IS HEREBY O.RDER.ED that:
1. All…
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…
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