giuffre-maxwell
gov.uscourts.nysd.447706.27.1
3 pg
…2016. The following Order is subject to the definitions, obligations and restrictions
imposed pursuant to Standing Order M10-468, as Revised. The Court has carefully considered
the Motion, and being otherwise fully advised in the premises, it is ORDERED AND…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…16 Page 2 of 21
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF, VIR…
giuffre-maxwell
gov.uscourts.nysd.447706.1334.0
1 pg
…NY 10007
Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff is filing a revised version of docket entry 700 pursuant to the Court’s January 8,
2024, Order. See ECF No. 1333.
Respectfully,
/s…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.0
1 pg
…York, NY 10007
Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff is filing a revised version of docket entries 173-8, 180-1, 180-2, 235-10 pursuant
to the Court’s January 4…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.0
1 pg
…York, NY 10007
Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff is filing a revised version of docket entry 450-1 pursuant to the Court’s January
10, 2024, Order. See ECF No. 1333…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.3
26 pg
…2 of 26
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
V.
Ghislaine Maxwell,
Defendant.
- - - - - - - - - - - - - -I
PLAINTIFF, VIRGINIA GIUFFRE'S F…
giuffre-maxwell
gov.uscourts.nysd.447706.76.2
21 pg
…16 Page 2 of 21
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF, VIR…
giuffre-maxwell
gov.uscourts.nysd.447706.1322.0
1 pg
…Giuffre v. Maxwell, Case No. 15-cv-7433-LAP
Dear Judge Preska,
Plaintiff is filing a revised version of docket entry 235-13 pursuant to the Court’s January
4, 2024, email correspondence with counsel.
Respectfully,
/s/ Sigrid S. McCawley…
giuffre-maxwell
gov.uscourts.nysd.447706.165.0
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1040.0
1 pg
…protocol.
To that end, we propose the following: that paragraph 2(c) be revised to provide 30 days
(rather than 14 days) for non-parties to submit a request for excerpts; that the first sentence of
paragraph 2(f) be…
giuffre-maxwell
gov.uscourts.nysd.447706.1192.0_3
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.21
19 pg
…16
Revised 03/04/201 I
Case 1:15-cv-07433-LAP Document 1328-21 Filed 01/05/24 Page 3 of 19
Date: 4/25/16 ROYAL PALM BEACH POLICE DEPARTMENT Page~ 1
Ti…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…first -- no,
20 you're correct, your Honor. That was our first order, and we
21 submitted a revised joint pretrial stipulation a couple weeks
22 ago, I believe it was.
23 THE COURT: Oh, I missed that. All right…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.5
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.76.0
2 pg
…to Defendant’s First Set of Discovery Requests to
Plaintiff, served on March 22, 2016.
3. Attached as Exhibit B is a true and correct copy of Plaintiff, Virginia Giuffre’s
Revised Disclosure Pursuant to Fed. R. Civ. P. 26…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.93.0
2 pg
…2
enforcement agency who is conducting an active criminal investigation of Ghislaine
Maxwell.
4. Attached as Exhibit D is a true and correct copy of pages 1, 16 and 17 from
Plaintiff’s Revised Disclosure Pursuant to Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.94.0
2 pg
…2
enforcement agency who is conducting an active criminal investigation of Ghislaine
Maxwell.
4. Attached as Exhibit D is a true and correct copy of pages 1, 16 and 17 from
Plaintiff’s Revised Disclosure Pursuant to Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.165.1
6 pg
…other communications legal advice and rendition of legal advice and communications re evidence. defense/commo with other
125 from 2011 - Present representation representation …
giuffre-maxwell
gov.uscourts.nysd.447706.232.1
…Giuffre
objects to this interrogatory in that it prematurely seeks expert witness disclosures. Ms. Giuffre
incorporates by reference herein her Revised Rule 26 disclosures, which includes her
computation of damages.
12. Identify any Health Care Provider from whom You received…
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