7. Attached hereto as Sealed Composite Exhibit 5 are true and correct copies of Excerpts from the June 1, 2016 Deposition of John Alessi. 8. Attached hereto as Sealed Exhibit 6 is a true and correct copy of June 20…
…Motion in Limine to Admit the “Black Book” as Evidence in Trial. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached hereto as Sealed Composite Exhibit 2 are true and correct copies of …
…to Defendant’s Motion in Limine to Exclude Victim Notification Letter. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached here to as Sealed Exhibit 2 is a true and correct copy of …
…in Limine to Permit Questioning Regarding Plaintiff’s Sexual History and Reputation. 3. Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of . 4. Attached hereto as Sealed Exhibit 2 is a…
…8, 2017 transcript of proceedings pursuant to this Court’s Protective Order. See Plaintiff’s proposed redactions attached hereto as Sealed Exhibit 1. Dated: November 28, 2017 Respectfully Submitted, By: /s Sigrid McCawley …
…for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of Rinaldo Rizzo. 4…
…privacy, and (3) requesting excerpts of sealed materials that mention them for their review (the “September 25 Email”). The parties dispute the procedural import of the September 25 Email under the Protocol governing the unsealing of documents in this action…
…2019 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Defendant Maxwell’s Letter Brief re Materials That Should Remain Sealed or Redacted Giuffre v. Ghislaine Maxwell, No…
…Court to Direct Defendant To Disclose All Individuals To Whom Defendant Has Disseminated Confidential Information. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of May 18, 2016, Correspondence from Jeff Pagliuca to Meredith Schultz. 4…
…In Support of Motion to Reopen Defendant’s Deposition Based on Late Production of New, Key Documents. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from May 18, 2016, Deposition of Johanna Sjoberg. …
…s Response in Opposition to Defendant’s Motion in Limine to Exclude in Toto Certain Deposition Designated by Plaintiff for Use at Trial. 3. - Attached hereto as Sealed Exhibit 1 is a true and correct copy of February 9, 2017…
…for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of Rinaldo Rizzo. 4…
…Declaration in Support of Plaintiff’s Motion to Compel Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from June 1, 2016…
…Testimony from Jeffrey Epstein for Purpose of Obtaining an Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of …
…Declaration in Support of Plaintiff’s Motion to Compel Communication All Work Product and Attorney Client Communications with Philip Barden. 3. Attached hereto as Sealed Composite Exhibit 1 is a true and correct copy of Defendant’s February 9, 2016…
…b) &(c) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of . …
…Declaration in Support of Plaintiff’s Motion to Compel Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from June 1, 2016…
…s Motion to Reopen Deposition of Plaintiff. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Judith Lightfoot Redacted Medical Records (Giuffre005431-005438). 4. Attached hereto as Sealed Exhibit 2 is a true and correct…
…2016, Order. 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of September 23, 2016, Transmittal Email serving Laura Menninger. 5. Attached here to as Sealed Exhibit 3 is a true and correct copy of a…
… Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of . I declare under penalty of perjury that the foregoing is true and correct. Case 1:15-cv-07433-LAP Document 690 Filed 03/03/17 Page…
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