… 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…
… 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…
…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: …
…by and through their undersigned counsel and pursuant to Rule 1.510, Florida Rules of Civil Procedure, hereby move for (1) partial summary judgment on the issue of the false and defamatory nature of the statements at issue in this…
… 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…
…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…
… 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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
… 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…
…TO FILING MOTIONS TO COMPEL Rule 37(a)(1) of the Federal Rules of Civil Procedure mandates that a motion to compel “must include a certification that the movant has in good faith conferred or attempted to confer with the…
…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, consensual sex. In support of her requests…
… 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…
…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…
…DEFENDANT’S COUNTER-DESIGNATIONS TO PLAINTIFF’S DEPOSITION DESIGNATIONS Defendant Ghislaine Maxwell, through her attorneys and pursuant to Rule 32 of the Federal Rules of Civil Procedures, hereby submits her counter-designations in accordance with the Court’s October 3…
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