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.447706.1320.10
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.447706.143.0
10 pg
…York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S REDACTED MOTION TO COMPEL DEFENDANT
TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL1
Plaintiff Virginia Giuf…
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
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.447706.1296.2
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
-
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…this Court
Ordered Defendant to sit for a second deposition because her refusal to answer questions posed
in her first Deposition (June 20, 2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet,
during her second deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.5
12 pg
…For example, in her
“Factual Background,” what Defendant characterizes as a “simulated sex act” for which Ms.
Giuffre “cried rape,” actually is a police report as follows:
“I then had [REDACTED] get off of [REDACTED]. I observed that [REDACTED] was…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…Whom Defendant Has Disseminated (sic) Confidential Information (Doc. #388),
and states as follows:
INTRODUCTION
Plaintiff’s Reply makes material misrepresentations of fact. Those misstatements cannot
stand in a filed, albeit redacted, pleading. Ms. Maxwell has never “admitted” to havin…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…the Court grants my application, I would also request that the Court
unseal the Requested Documents along with all of the references to them in my motion papers
that are being redacted from the public docket.
4.
2
5. …
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…document. Instead, the court found
that the entire report was a judicial document, but in weighing the applicable countervailing
interests found that one portion of the report should be redacted. Amodeo, 71 F.3d at 1051–52.15
Finally, Doe…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.4
106 pg
…Ms. Maxwell, the redacted
4 MR. PAGLIUCA: I'm going to object 4 information is redacted because it reveals
5 to you interrupting the witness who was 5 the name of a minor, someone who is under the
6 answering…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…with
13 respect to John Doe no. 3, privacy interest, whatever, whatever
14 and file that redacted document on the public docket sheet.
15 Right? Does that make sense? Okay.
16 What else? May I have your responses?
17 Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.1
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…privileged.
13 We just received an opposition to our motion which was
14 filed last night after close of business and we've been
15 reviewing it, but much of the substance of it is redacted out
16 pursuant, presumably…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.13_5
465 pg
…report, Ms. Maxwell, the redacted
4 information is redacted because it reveals
5 the name of a minor, someone who is under the
6 age of 18.
7 On page 28, in the third paragraph,
8 about halfway down, it…
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