giuffre-maxwell
gov.uscourts.nysd.447706.1331.34
10 pg
…hassle. Due lo me applying so late I am unable to send my application on line due to
technicalities which is very frustrating considering the whole thing has been fuled out and is
v Smort views waiting to be submitted…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…this review.
15 THE COURT: Bless you, my daughter.
16 MS. McCAWLEY: A few ideas that we have come up
17 with -- we have submitted the letter to you, obviously, which
18 poses an approach dealing with the non-parties…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…MCCAWLEY: Your Honor, I don't have the pretrial
12 order that we submitted in front of us. My recollection is we
13 did put in a date for the exchange of exhibits internally and
14 then submission to the…
giuffre-maxwell
gov.uscourts.nysd.447706.1323.0
2 pg
…unsealing.
As such, Dershowitz respectfully requests that Docket Entry 1026-3 be unsealed.
[SIGNATURE PAGE TO FOLLOW]
Case 1:15-cv-07433-LAP Document 1323 Filed 01/04/24 Page 2 of 2
Respectfully Submitted,
AIDALA, BERTUNA…
giuffre-maxwell
gov.uscourts.nysd.447706.27.0
3 pg
…468, as Revised.
Case 1:15-cv-07433-RWS Document 27 Filed 01/11/16 Page 2 of 3
Dated: January 11, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawley
…
giuffre-maxwell
gov.uscourts.nysd.447706.235.2
4 pg
…April 27th, 2016.
All documents withheld on the basis of the “public interest privilege,” other
than Plaintiff’s actual statements to any law enforcement agency, which are to
be submitted for in camera review forthwith. See Resp. to RFPs…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…the plaintiff
4 to law enforcement authority and those statements, if there are
5 such, will be submitted in camera, and I will review them.
6 I hope that clears up our problems. Tell me if I have
7 failed…
giuffre-maxwell
gov.uscourts.nysd.447706.1247.0
25 pg
…Maxwell, 929 F.3d 41, 50 (2d Cir. 2019). “Materials
submitted in connection with, and relevant to, discovery motions, motions in limine, and other
non-dispositive motions are subject to a lesser—but still substantial—presumption of public
access.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.8
16 pg
…Giuffre should be allowed to take three more depositions than
the presumptive ten deposition limit – a total of thirteen depositions.
Dated: June 14, 2016.
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
…
giuffre-maxwell
gov.uscourts.nysd.447706.1078.1
8 pg
…of
7 8
The Honorable Alison J. Nathan
July 21, 2020
Page 7
Respectfully Submitted,
Jeffrey S. Pagliuca
cc:
Alex Rossmiller
Allison Moe
Maurene Comey
U.S. Attorney’s Office for the Southern District of New York
Mark Cohen
Christian…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…Ms. Giuffre has
provided detailed information about each individual she has deposed already and still seeks to
depose.
9
Case 1:15-cv-07433-LAP Document 1256-11 Filed 05/03/22 Page 14 of 15
Respectfully Submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…Giuffre respectfully requests that she be allowed to take a total seventeen depositions
in this case.
Dated: May 27, 2016
Respectfully Submitted,
BOIES, SCHILLER & FLEXNER LLP
By: /s/ Sigrid McCawle…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…taking Defendant’s deposition.
CONCLUSION
Defendant should be ordered to sit for a follow-up deposition and directed to answer
questions regarding the topics enumerated above.
Dated: July 29, 2016
Respectfully Submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.9
10 pg
…they not re-litigate any issues previously litigated by Jane Doe #1 and Jane Doe #2. A
proposed order to that effect is attached to this pleading.
DATED: December 30, 2014
Respectfully Submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…children of her or Mr. Epstein’s friends.
16
Case 1:15-cv-07433-LAP Document 1325-19 Filed 01/04/24 Page 19 of 20
Dated: June 29, 2016
Respectfully submitted,
/s/ Laura A. Menninger
…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…taking Defendant’s deposition.
CONCLUSION
Defendant should be ordered to sit for a follow-up deposition and directed to answer
questions regarding the topics enumerated above.
Dated: July 29, 2016
Respectfully Submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1285.0
6 pg
…line 24 through page 6, line 16. See Docs. 1283 & 1284 (notices of
filing official transcript).
Very respectfully submitted,
AXS LAW GROUP, PLLC
2121 NW 2nd Avenue, Suite 201
…
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…Virginia Giuffre.
18 With all due respect to my colleague, I think she read
19 a different complaint than the one submitted in this case. She
20 left out significant factual details from the complaint that
21 plead actual defamation…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…Ms. Maxwell requests costs incurred in
bringing this Motion based on counsel’s improper instructions not to answer relevant and non-
privileged questions.
Dated: July 8, 2016
Respectfully submitted,
/s/ Laura A. Menninger
…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…That's troubling as well because we went through
2 litigation in this case about our access to alleged
3 public-interest privileged documents that were not turned over
4 to us but were submitted in camera to the Court…
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