…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REDACTED REPLY IN SUPPORT OF MOTION TO COMPEL DEFENDANT TO ANSWER DEPOSITION QUESTIONS Plaintiff Virginia Giuffre, by and …
… 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…
…SUBPOENA TO ATTEND ??ATTEND AND PRODUCE To: __Jane Doe #3_(address redacted for purpose of court filing) You are ordered to attend and give testimony at the District Court of Fremont County, located at: 136 Justice Center Road, Canon City…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…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…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…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…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…04/03/17 03/23/17 Page Page 22 of of 44 TABLE OF CONTENTS and PAGES 1-10 REDACTED Case 1:15-cv-07433-LAP Document 827 Fil…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…the address book contained the circled names of many celebrities and other individuals, including , among others.8 Even the late name and redacted phone number was in the “black book.” And yet, Mr. Cassell seems to have falsely assumed that…
…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…
…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…
…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…
…649 F.2d 646 (9th Cir. 1980) (“While discovery is a valuable right and should not be unnecessarily restricted, the ‘necessary’ restriction may be broader when a non-party is the target of discovery.”). Courts have routinely denied the discovery…
…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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