giuffre-maxwell
gov.uscourts.nysd.447706.223.2
7 pg
…06/16/16 Page 2 of 7
From: Sigrid McCawley
Sent: Thursday, April 07, 2016 12:01 PM
To: Martin Weinberg
Subject: RE: Giuffre v. Maxwell
No -I can wait until tomorrow. Thank you for following up.
Sigrid
Sigrid S…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…responsive were reviewed by
counsel and either produced or placed on a privilege log. The First Responses were the subject
of litigation in March and April 2016. This Court limited the scope of a number of the requests
(see Transcript…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.8
6 pg
…McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell ([email protected])
Subject: RE: Conferral regarding forensic search
Follow Up Flag: Follow Up
Flag Status: Flagged
Laura,
Please see my additions in-line, in black, below to your email sent yesterday…
giuffre-maxwell
gov.uscourts.nysd.447706.77.0
2 pg
…15-cv-07433-RWS
GHISLAINE MAXWELL,
Defendant.
--------------------------------------------------X
Notice of Submission of Declaration in Support of Defendant’s In Camera
Submission in Opposition to Plaintiff’s Motion to Compel the Production of
Documents Subject to Improper Claim of Privilege
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.30
6 pg
…McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell ([email protected])
Subject: RE: Conferral regarding forensic search
Follow Up Flag: Follow Up
Flag Status: Flagged
Laura,
Please see my additions in-line, in black, below to your email sent yesterday…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.28
24 pg
…relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of…
giuffre-maxwell
gov.uscourts.nysd.447706.130.0
5 pg
…a judge receives
an unauthorized ex parte communication bearing on the substance of a matter, the
judge should promptly notify the parties of the subject matter of the
communication and allow the parties an opportunity to respond, if requested.
Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.223.1
14 pg
…relating to the place of compliance;
Rule ·j5(d), relating to your protection as a person subject to a subpoena; and Rul 45(0) and (g), relating to your duty to
respond to this subpoena and the potential consequences of…
giuffre-maxwell
gov.uscourts.nysd.447706.563.0
10 pg
…Civ. P.
32(a)(8)’s provision dealing with a “deposition taken in an earlier action,” prior deposition
testimony can only be used where the earlier deposition involved the same parties and the same
subject matter. Because those conditions are…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.22
22 pg
…THIS CASE, I WAS REFERRED TO A SUBJECT B't
THE NAME OF NICHOLAS SILVAGE AS THE PERSON WHO MIGHT KNOW THE LAST NAME
OF A SUBJECT IDENTIFIED ONLY.,~ /,JOSH IN THE REPORT.
ON 7-29- 98, I RESPONDElYTO…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.31
24 pg
…docume11t:,
nn,,t prod11cc: tht.:m ~, 1hcy nrc kq11 ill lhc ordin:,ry coun,c ol bt1;incs~ or
(di Protecting a l'ct'SQn Subject to a Subpoena; Enl"orccmcnt. must 11rganizc and label them to cnt~·csponcl…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.32
27 pg
…relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…has thus far
produced 7,000 documents which consist of 22,000 pages.
However, certain documents requested by Plaintiff which are located on servers in France are
subject to European/France’s blocking laws which, as a matter of law…
giuffre-maxwell
1320-32
27 pg
…relating to the place of compliance;
Rule 45(d), relating to your protection as a person subject to a subpoena; and Rule 45(e) and (g), relating to your duty to
respond to this subpoena and the potential consequences of…
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