giuffre-maxwell
gov.uscourts.nysd.447706.971.0
1 pg
…Preska:
This firms represents the plaintiff, Virginia Giuffre. We welcome a conference with the
Court tomorrow at 2:15 as scheduled. If the Court is inclined to move the conference, we request
that it be scheduled as soon as possible…
giuffre-maxwell
gov.uscourts.nysd.447706.223.4
2 pg
…if you will agree to schedule the depo near his Virgin Island residence for a
mutually agreeable date in June I can accept service so long as it is further agreed that
the acceptance of service is subject to a…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.11_1
21 pg
…the parties to submit search terms to the Court on August 1, 2016,
advising that “[a] briefing schedule and the submission date will be set after search terms are
determined.” (DE 301).
Pursuant to this Court’s July 22, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1101.0_1
1 pg
…For the foregoing reasons, the Court should proceed with the unsealing process, set a
briefing schedule for the next set of sealed motions, and order the Original Parties to serve the
remaining Non-Parties with Notice, as outlined in Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.15
5 pg
…to discuss the excluded terms to determine if there are agreeable additions. In light
of the deposition scheduled for Friday and the time it takes to run searches, any call would need to be set prior to noon
MT tomorrow…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.2
21 pg
…the parties to submit search terms to the Court on August 1, 2016,
advising that “[a] briefing schedule and the submission date will be set after search terms are
determined.” (DE 301).
Pursuant to this Court’s July 22, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.19
21 pg
…the parties to submit search terms to the Court on August 1, 2016,
advising that “[a] briefing schedule and the submission date will be set after search terms are
determined.” (DE 301).
Pursuant to this Court’s July 22, 2016…
giuffre-maxwell
gov.uscourts.nysd.447706.438.0
1 pg
…moot and that Ms.
Giuffre will produce the settlement agreement to defense counsel immediately after the
endorsement of this letter. The Parties jointly request that the hearing scheduled for next week
be vacated.
Respectfully submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.87.0
4 pg
… Counsel for Ms. Maxwell are both unavailable to appear in New York on
April 13, 2016.
5. Mr. Pagliuca is scheduled to appear on that date before the Hon. Christine
M. Arguello, U.S. District Court for the District of…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…a few preliminaries with you all.
12 First of all, this is being treated as it was
13 scheduled, that is as a motion with respect to discovery and
14 also the timing of the deposition and maybe there are…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…B. The Requested Stay is for a Short Period of Time
Pursuant to Rule 6.1(b) of the Local Rules of this Court, briefing on the Motion to
Dismiss is scheduled to be completed on Monday, December 28. Accordingly…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…a few preliminaries with you all.
12 First of all, this is being treated as it was
13 scheduled, that is as a motion with respect to discovery and
14 also the timing of the deposition and maybe there are…
giuffre-maxwell
gov.uscourts.nysd.447706.413.0
2 pg
…All remaining deadlines will be unaffected by this
agreement.
WHEREFORE, the parties request that the Court adopt the proposed schedule and modify
the Court’s Order of August 1, 2016 to reflect the above deadline modification.
Respectfully Submitted,
/s/ Bradley…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…Maxwell has exhausted every possible source for obtaining this information.
17
Case 1:15-cv-07433-LAP Document 1325-1 Filed 01/04/24 Page 20 of 21
and the deposition would be scheduled at a mutually agreeable time…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…Edwards agreed that productions would be
made prior to Ms. Maxwell’s second deposition, scheduled by agreement on July 22, 2016.
Based on this discussion, defense counsel was blindsided when they received the Motion for Sanctions,
anticipating that they would…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.1
8 pg
…See June 20, 2016, Unredacted Order, at p. 9-
10. This deposition is currently scheduled for July 22, 2016. Ms. Giuffre is forced to take this
deposition without the discovery this Court ordered, and therefore, will not be able to…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…Edwards agreed that productions would be
made prior to Ms. Maxwell’s second deposition, scheduled by agreement on July 22, 2016.
Based on this discussion, defense counsel was blindsided when they received the Motion for Sanctions,
anticipating that they would…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…Edwards agreed that productions would be
made prior to Ms. Maxwell’s second deposition, scheduled by agreement on July 22, 2016.
Based on this discussion, defense counsel was blindsided when they received the Motion for Sanctions,
anticipating that they would…
giuffre-maxwell
gov.uscourts.nysd.447706.343.0
8 pg
…Ms. Giuffre
4
Case 1:15-cv-07433-LAP Document 343 Filed 08/09/16 Page 5 of 8
is doing here.
After counsel for Defendant refused to work with Ms. Giuffre to schedule Mr. Gow’s
deposition, Plaintiff…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
… BACKGROUND
Plaintiff first identified Sarah Ransome as a witness on January 13, 2016, a mere two
months before trial was scheduled to begin. In evaluating the relevance of the documents sought
in the third-party subpoena to Ms. Ransome…
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