giuffre-maxwell
gov.uscourts.nysd.447706.1256.23
4 pg
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…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.44_1
3 pg
…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 copy of Judith
Lightfoot’s June 27…
giuffre-maxwell
gov.uscourts.nysd.447706.684.0
3 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.733.0
3 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.739.0
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.933.0
3 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.17
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…request for pre-Answer discovery,
Giuffre expects that she will also be allowed to identify and publish sealed materials in response
to Dershowitz’s forthcoming counterclaims.
Sincerely,
/s/ Sigrid McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.2_1
3 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.1
3 pg
…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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.14
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.8
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.12
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.651.0
3 pg
…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
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.20
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.6_2
4 pg
…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 .
…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.34
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.44
4 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.690.0
3 pg
… 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…
giuffre-maxwell
gov.uscourts.nysd.447706.471.0
3 pg
…Testimony of Jeffrey Epstein.
3. 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.
…
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