giuffre-maxwell
gov.uscourts.nysd.447706.1003.0
1 pg
…A]ll of the documents in question are judicial documents, and accordingly the
entire record should be unsealed, subject to redactions similar to what the Second Circuit applied.”).
Giuffre objects, however, to the selective unsealing that would occur if only…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.37
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.3
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.71.2
45 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.76.1
45 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
1320-37
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.235.3
48 pg
…of relevant documents, including pertinent
insurance agreements, and other physical evidence, or information of a similar nature.” Local
Civil Rule 33.3(a). Instead, they seek information under subsections (b) and (c) of Local Civil
Rule 33.3, and therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.87.0
4 pg
…s Motion to Compel.
9. Ms. Maxwell anticipates filing a similar opposition to the appearance of
Bradley Edwards, who just filed a motion to appear pro hac vice, and would ask that it be
contemporaneously with the other motions on…
giuffre-maxwell
gov.uscourts.nysd.447706.18.0
5 pg
…that the Complaint has various pleading deficiencies and that the alleged
defamatory statements are protected by not one, but two, applicable privileges. Courts in this
district have stayed discovery under similar circumstances. See e.g., Integrated Sys. and Power,
Inc…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.2
13 pg
…characters to be applied
in the manner of the examples above. Please apply them as such with whatever characters is
required by the software/platform that you will be using.
Similarly, regarding how the terms are combined (AND or OR…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.2_1
10 pg
…characters to be applied
in the manner of the examples above. Please apply them as such with whatever characters
is required by the software/platform that you will be using.
Similarly, regarding how the terms are combined (AND or OR)…
giuffre-maxwell
gov.uscourts.nysd.447706.121.0
10 pg
…information . . . and seek to agree on the scope of each party’s rights and responsibilities.”
Similarly, Standing Order M10-468, In re: Pilot Project Regarding Case Management
Techniques for Complex Civil Cases in the Southern District of New York, requires…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.13
13 pg
…characters to be applied
in the manner of the examples above. Please apply them as such with whatever characters is
required by the software/platform that you will be using.
Similarly, regarding how the terms are combined (AND or OR…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.10
469 pg
…The witness has expressed to
21 me fears of harassment and the
22 belief that she's being followed,
23 and my understanding is that
24 there are other witnesses that
25 have had similar fears and
Highly Confidential
…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…she's being followed,
23 and my understanding is that
24 there are other witnesses that
25 have had similar fears and
MAGNA9 LEGAL SERVICES
Case 1:15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 17…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Dec. at Exhibit 1, Ransome Tr. at 183-184, 189.
Request 27 - She testified that she has never written a book or any similar writings about
her time with Defendant. See Pottinger Dec. at Exhibit 1, Ransome Tr. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…electronic message via apps such as Facebook, What's
App, Snapchat, Linked.IN or similar, or other media or Documents.
6. "Virginia Ro eans Virginia Giuffre, formerly known as Virginia Roberts,
date of birth the Plaintiff in the above captioned…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…be unable to answer questions about what
Defendant thought about his inquiry, or what she did next, and similar questions.
Similarly, only Defendant can testify to her understanding of why she was explaining herself to
Epstein on April 22, 2015…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Any application for college, university, or any other post-secondary institution, or
technical college, fashion college, modeling training or any similar institution, submitted by You
or on Your behalf during the years 2005 – present. (Complaint ¶ 37, 53-55; financial motivation…
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