…be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. "I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage…
…33 and 34, defendant Ghislaine Maxwell propounds this First Set of Discovery Requests to Plaintiff Virginia Giuffre. Plaintiff shall respond in writing to the Interrogatories, and shall produce documents as requested, within thirty (30) days of service at the offices…
…Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: 1. “Agent” shall mean any agent, employee, officer, director, a…
…Sent: Monday, 7 March 2011 8:46 PM To : Virginia Giuffre Subject: Re: All understood. A lot of people are rooting for you . You must do what is best for you and your family. Where shall we meet? (Glorious weather ... …
…this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. See Protective Order (DE 62) signed on March 17, 2016…
…Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: 1. “Agent” shall mean any agent, employee, officer, director, a…
…and Fed. R. Civ. P. 4l(a)(l)(A)(ii), this action shall be DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs. Dated: May 24, 2016 Respectfully Submitted, FARMER, JAFFE, WEIS SING …
…be withdrawn have simply been ignored. In the circumstances, Ms Maxwell is now proceeding to take legal action against those newspapers. I understand newspapers need stories to sell copies. It is well known that certain newspapers live by the adage…
…parties and Fed. R. Civ. P. 41(a)(1)(A)(ii), this action shall be DISMISSED WITH PREJUDICE, with each party to bear its own attorneys' fees and costs. Dated: May 24, 2016 Respectfully Submitted, FARMER, JAFFE, WEISSING …
…the following words and phrases have the following meanings: 1. “Plaintiff” in the above captioned action shall mean the plaintiff Virginia Giuffre formerly known as Virginia Roberts. 2. “Defendant” in the above captioned action shall mean the defendant Ghislaine Maxwell…
…question, shall be reserved to the time of the 9 trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to and 12 signed before any officer authorized to 13 administer an oath, with…
…question, shall be reserved to the time of the 9 trial. 10 IT IS FURTHER STIPULATED AND AGREED 11 that the within deposition may be sworn to and 12 signed before any officer authorized to 13 administer an oath, with…
…lcr(a wilcyn:in.cum Miami, Florida 33156 WILEY REIN, LLP Rcncc.nailidc;,klcgal.co1n 177 6 K Street NW Shellv.zambo(c1 csklegal.com Washington, D.C. 20006 Counsel for Alan Dershowitz Counsel for Alan Dersh…
…4610422, at *7 (S.D.N.Y. July 23, 2015) (Sweet, J.) (ordering that “the parties shall meet and confer in order to set a[n electronic] search protocol”). A case need not be designated “complex” for Fed. R. Civ…
…this matter, it shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York. See Protective Order (DE 62) signed on March 17, 2016…
…2(c), a Non-Party may request excerpts by fax, mail or email. “Upon receipt of the request, the Original Parties shall confer and cause the Excerpts to be served via U.S. mail or e-mail.” Under ¶ 2(d), “…
…any other notary public authorized by law to take depositions. The oral examination will continue from day to day until completed. The video operator shall be provided by Magna Legal Services. This deposition is being taken for the purpose of…
…Such a statement shall include citations to all statutes relied on and relevant facts as to citizenship and jurisdictional amount. 3 Case 1:15-cv-07433-LAP Document 622 Filed 02/10/17 Page 4 of 17 4 Case 1…
…by Paragraph 2(d) of the Protocol. Accordingly, the September 25 Email submitted by Does 1 and 2 shall not be construed as a formal objection to unsealing under Paragraph 2(d) of the Protocol. Pursuant to Paragraph 2(d)…
…In both of these instances, Churcher is not acting as a journalist – she is acting as a friend and advisor to Plaintiff on how to drop names – truth be damned – to try to sell Plaintiff’s book. As Churcher - puts…
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