giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
giuffre-maxwell
gov.uscourts.nysd.447706.71.3
40 pg
…15-cv-07433-RWS Document 71-3 Filed 03/23/16 Page 26 of 40
request as it seeks documents of sealed juvenile records, and the only means of obtaining
such records are either through court order or illegal means…
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.447706.813.0
3 pg
…hereby files this proposed redactions of the Order Denying
Defendant’s Motion for Summary Judgment. See Plaintiff’s proposed redactions attached hereto
as Sealed Exhibit 1.
Dated: March 29, 2017
Respectfully Submitted,
By: /s Sigrid McCawley
…
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.447706.933.0
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.447706.1331.1
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.447706.1330.12
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.447706.1219.34
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.
…
giuffre-maxwell
gov.uscourts.nysd.447706.564.0
3 pg
…of Virginia Giuffre in an Unrelated Case.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
.
I declare under penalty of perjury that the foregoing is true and correct.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.4
3 pg
…Plaintiff’s Reply to Motion to
Compel Communication All Work Product and Attorney Client Communications with Philip
Barden.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of January 6, 2017
Declaration of Philip Barden.
4…
giuffre-maxwell
gov.uscourts.nysd.447706.698.0
3 pg
…to Motion to
Compel Communication All Work Product and Attorney Client Communications with Philip
Barden.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
4. Attached hereto as Sealed Composite Exhibit 2
I declare under…
giuffre-maxwell
gov.uscourts.nysd.447706.713.0
3 pg
…Support of Response to Jeffrey Epstein’s Motion
to Quash Trial Subpoena.
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.447706.641.0
4 pg
…this Declaration in Support of Motion for Protective Order
for Non-Party Witness.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of
.
4. Attached hereto as Sealed Exhibit 2 are true and correct copies of
…
giuffre-maxwell
gov.uscourts.nysd.447706.828.0
3 pg
…in Support of
Motion in Limine to Preclude Defendant from Calling Plaintiff’s Attorneys as Witnesses at Trial.
3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Paul G. Cassel,
Esq.’s Curriculum Viate.
4…
Comments