…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…
…Suite 1200 1 Pursuant to conferral with opposing counsel, Plaintiff has revised the first paragraph of this brief, as well as the second-to-last paragraph of Section I of this brief out of a concern Defendant raised with the…
…Suite 1200 1 Pursuant to conferral with opposing counsel, Plaintiff has revised the first paragraph of this brief, as well as the second-to-last paragraph of Section I of this brief out of a concern Defendant raised with the…
…Suite 1200 1 Pursuant to confen-al with opposing counsel, Plaintiff has revised the first paragraph of this brief, as well as the second-to-last paragraph of Section I of this brief out of a concem Defendant raised with…
…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…
…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…
…Suite 1200 1 Pursuant to conferral with opposing counsel, Plaintiff has revised the first paragraph of this brief, as well as the second-to-last paragraph of Section I of this brief out of a concern Defendant raised with the…
…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…
…041883 Date: 04/25/2016 Revised 03/04/2011 Case Case OQS - Viewing 1:15-cv-07433-LAP Number 9804188…
…171, and 183. 5 The Court sought the parties' views as to how to 6 streamline the unsealing process, and the revised protocol we 7 have now settled upon generally works as follows. Rather than 8 reviewing objections by document…
…171, and 183. 5 The Court sought the parties' views as to how to 6 streamline the unsealing process, and the revised protocol we 7 have now settled upon generally works as follows. Rather than 8 reviewing objections by document…
…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 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…
…Giuffre revised the protocol for challenging the designation of a document as “confidential” in order to stream line that process as follows: “(a) A Party shall not be obligated to challenge the propriety of any designation of discovery material under…
…her physical safety based on credible threats to the same. Ms. Giuffre refers to the list of witnesses identified in her Revised Rule 26 Disclosures. 9. Identify any Employment You have had from 1996 until the present, including without limitation…
…information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Ms. Giuffre refers to the list of witnesses identified in her Revised Rule 26 Disclosures. Also, notwithstanding previously-noted objections, Ms…
…further information through expert disclosure. See McCawley Decl. at Exhibit 2, Plaintiff’s Revised Rule 26 Disclosures, and Exhibit 3, Addendum to Rule 26 Disclosures. C. Plaintiff’s Non-Economic Computation of Damages Complies with Rule 26 As stated above…
…robiejenna defense/commo 7 2/21/2015 16:45 Sigrid McCawley [email protected] [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 msg…
…utah.edu, defense/commo 7 2/21/2015 16:45 Sigrid McCawley [email protected] Discussion of evidence among client and attorneys n interest Withheld 2 …
…seeks information protected by the attorney-client/work product privilege, and any other applicable privilege stated in the General Objections. Ms. Giuffre refers to the list of witnesses identified in her Revised Rule 26 Disclosures. Also, notwithstanding previously-noted objections…
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