…Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this motion to maintain her designation of her Third Revised Rule 26 Disclosures as confidential under the terms of the parties’ Protective Order. BACKGROUND On June 1, 2016, Ms…
…sealed in Maxwell.” DE 233, at 2. The Court’s revised language underscored that “the parties may only agree to remove confidentiality designations for Ms. Giuffre’s personal documents” from Maxwell, “i.e., those bearing her bates stamp in Maxwell…
…correct copy of Addendum to Plaintiff’s Rule 26 Initial Disclosures, served March 22, 2016. 5. Attached as Exhibit D is a true and correct copy of Plaintiff, Virginia Giuffre’s Revised Disclosure Pursuant to Fed. R. Civ. P. 26…
…Attornty Work Product Placed At Issue by Plaintiff and Her Attorney. 2. Attached as Exhibit A is a true and correct copy of excerpts categorically logged entries from Plaintiff Giuffre's Revised Supplemental Privilege Log dated April 29, 2016. 3…
…correct copy of Addendum to Plaintiff’s Rule 26 Initial Disclosures, served March 22, 2016. 5. Attached as Exhibit D is a true and correct copy of Plaintiff, Virginia Giuffre’s Revised Disclosure Pursuant to Fed. R. Civ. P. 26…
…cv-07433-LAP Document 1320-36 Filed 01/03/24 Page 3 of 3 14. Attached as Exhibit N (filed under seal) is a true and correct copy of Plaintiff, Virginia Giuffre's Third Revised Disclosure Pursuant to Fed. R…
…Doe’s identifying information redacted (unless such information has been unsealed already by the Court in Maxwell). The parties shall file a revised protective order with this language appended to the definition of “Confidential Information.” SO ORDERED. Dated: New York…
…cv-07433-LAP Document 1320-36 Filed 01/03/24 Page 3 of 3 14. Attached as Exhibit N (filed under seal) is a true and correct copy of Plaintiff, Virginia Giuffre's Third Revised Disclosure Pursuant to Fed. R…
…President - Clinton. No Notice of Deposition has been served and no scheduling of his deposition has commenced. Indeed, President Clinton first appeared on Plaintiff’s Third Revised Rule 26 Disclosures two weeks ago on June 1. Then, last week, in…
…16 Compel Responses to Defendant's First Set of Discovery Requests to Plaintiff 94‐1 Exhibit D 4.13.16 Defendant's Revised Page 9 to Defendant's Reply In Support of Motion to Compel 99 …
…President - Clinton. No Notice of Deposition has been served and no scheduling of his deposition has commenced. Indeed, President Clinton first appeared on Plaintiff’s Third Revised Rule 26 Disclosures two weeks ago on June 1. Then, last week, in…
…draft was, at first, ignored. When pressed, Plaintiff provided a revised 1 protective order that contains traps and loopholes rendering it meaningless. Thus, Ms. Maxwell was forced to file her request for a protective order with the Court. Ms. Maxwell…
…152 . Maxwell has urged that these conclusions at the motion to dismiss stage should be revis ited and revised when considering the surrunary judgment motion sinc e t he standard for decid ing a Rule 12(b) (6) motion is…
…THE PROTOCOL FOR UNSEALING CANNOT BE REVISED OR REVISITED WITHOUT FULL BRIEFING AND THEN RE-NOTICE TO ALL OF THE NON- PARTIES OF ANY CHANGES The request for an affirmative modification of the unsealing protocols by plaintiff and the Miami…
…requests and thus far has produced 4,134 pages of documents. Defendant’s Position: Defendant says Plaintiff should not have listed certain objections like “agency” or “investigative privilege.” Reality: Plaintiff agreed during the meet and confer to revise…
…second case. And I 11 think when you look through, in order to do that, your Honor 12 would have to revise, substantially revise the protective order 13 and the four factors that guide it. None of them, none of…
…victims, and they are confident that compliance here will not be a problem. Therefore, the Court should not revise the previously-entered Protective Order to impose such disabling conditions on Professor Cassell and Mr. Edwards. CONCLUSION For all these reasons…
…Mr. Dershowitz said he believes Ms. Giuffre “and/or her representatives” have revived the story of Mr. Epstein’s criminal investigation and “[a]t least one reporter” told Mr. Dershowitz that “she has been given materials that are subject to…
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