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.447706.1334.0
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.447706.232.3
2 pg
…07433-RWS
v.
Ghislaine Maxwell,
Defendant..
________________________________/
ADDENDUM TO PLAINTIFF’S RULE 26 INITIAL DISCLOSURES
Treating physicians who would have relevant information regarding the computation of
damages in Section C of the Revised Disclosures pursuant to Rule 26 dated March 11…
giuffre-maxwell
gov.uscourts.nysd.447706.201.0
5 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.69.3
3 pg
…07433-RWS
v.
Ghislaine Maxwell,
Defendant..
________________________________/
ADDENDUM TO PLAINTIFF’S RULE 26 INITIAL DISCLOSURES
Treating physicians who would have relevant information regarding the computation of
damages in Section C of the Revised Disclosures pursuant to Rule 26 dated March 11…
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.447706.156.0
3 pg
…in support of
Ms. Maxwell’s Motions to Compel Non-Privileged Documents.
2. Attached as Exhibit A is a true and correct copy of Plaintiff Virginia Giuffre's
Revised Supplemental Privilege Log dated April 29, 2016, served on April 29…
giuffre-maxwell
gov.uscourts.nysd.447706.1232.0
3 pg
…28, 2021, order directing the Parties
to “submit a revised version of the protocol” and “a briefing schedule to address the objections of
the first eight non-party objectors.” ECF No. 1230 at 3.
Plaintiff’s Position
On October 5…
giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…3, 2017 and
submitted to the Court by April 15, 2017;
The Revised Joint Pre-trial Order shall be submitted by April 15, 2017;
Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by
April 24, 2017…
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.447706.65.0
2 pg
… Case 1:15-cv-07433-LAP Document 65 Filed 03/22/16 Page 2 of 2
4. Attached as Exhibit C is a true and correct copy of Plaintiff, Virginia Giuffre’s
Revised Disclosure Pursuant to Fed. R. Civ…
giuffre-maxwell
gov.uscourts.nysd.447706.423.0
3 pg
…2009.
5. Attached as Exhibit D (filed under seal) is true and correct copy of Plaintiff’s Fourth
Revised Rule 26(a) Disclosures served on June 24, 2016.
I declare under penalty of perjury that the foregoing is true and…
giuffre-maxwell
gov.uscourts.nysd.447706.1254.0
18 pg
…the parties' view
10 as to how to streamline the unsealing process, and the revised
11 protocol we have settled upon generally works as follows.
12 Rather than reviewing objections by document, the Court is
13 reviewing objections by objector…
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.447706.639.0
2 pg
…objections.
The parties expect to submit in the next few days a proposed schedule for hearings on
remaining legal issues in this matter and a revised proposed scheduling order in light
of the new anticipated trial date of May 15…
giuffre-maxwell
gov.uscourts.nysd.447706.69.0
4 pg
…Daily Mail Article.
4. Attached hereto as Exhibit 2, is a true and correct copy of Plaintiff’s Revised Rule
26 Disclosures.
5. Attached hereto as Exhibit 3, is a true and correct copy of Plaintiff’s Addendum
to Rule…
giuffre-maxwell
gov.uscourts.nysd.447706.1107.0
2 pg
…current
address for a given Non-Party, Doe 1 shall be provided the
Non-Party Notice at his/her new address going forward.
A revised Order and Protocol for Unsealing Decided Motions,
reflecting the changes above, will be docketed.
SO…
Comments