giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…modifying its Order of October 3, 2016, ECF
#455 for the following reasons:
Subsequent to the hearing on February 16, 2017 the parties have conferred extensively
about the viability of the existing case management deadlines. The parties agree that the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.8
10 pg
…to
Reopen Defendant’s Deposition Based on Defendant’s Production of New, Key Documents because
Defendant produced documents subsequent to her deposition about which she should answer
questions. The Court has already ruled that reopening a party deposition is appropriate…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…that time, they say. The lawyers also
want to discuss subsequent interactions with their client in New York City later that year, the letter says.
"The interview could be conducted at a time and place of your choosing, and with…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.19
20 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s Interrogatories
are based on information currently known to her and are given without waiving Ms. Maxwell’s
right to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…the motion
12 to strike the testimony that you allowed over the
13 ruling.
14 SPECIAL MASTER: And there's a series of
15 those things that might need to be cleaned up in a
16 subsequent sitting.
17 MR…
giuffre-maxwell
gov.uscourts.nysd.447706.1231.0
3 pg
…Giuffre’s and Ms. Maxwell’s briefs
responding to the Does’ objections (along with the Court’s subsequent ruling) will be publicly
filed. Any filing that is “relevant to the performance of the judicial function and useful in the
judicial…
giuffre-maxwell
gov.uscourts.nysd.447706.107.0
4 pg
…Obection to this motion was lodged by Ms. Maxwell on April 8, 2016, Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v…
giuffre-maxwell
gov.uscourts.nysd.447706.1228.0
4 pg
…Id. This language is
contained in the version of the Protocol which we understand was mailed to all Does. See DEs
1115–16.
Subsequent to the filing of our letter, we were directed to the Court’s October 20, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.25
9 pg
…at the time, who
6 initially had told me that he would make everyone
7 available for an interview. And subsequent
8 conversations later, no one was available for
9 interview and everybody had an attorney, and I was
10…
giuffre-maxwell
gov.uscourts.nysd.447706.104.0
4 pg
…Obection to this motion was lodged by Ms. Maxwell on April 8, 2016, Doc. # 88.
Subsequent to the filing of the Objections, Ms. Maxwell obtained a statement issued by
Mr. Cassell and Mr. Edwards related to Edwards and Cassell v…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…case.
3. Ransome responds to the requests as she reasonably interprets and understands the
requests. Should Defendant subsequently assert an interpretation of any individual request that
differs from her understanding, she reserves the right to supplement the responses.
4. To…
giuffre-maxwell
gov.uscourts.nysd.447706.26.1
26 pg
…had publicly
defamed her in statements made by individuals operating
at his direction or within scope of their employment. Cases that cite this headnote
Complaint was subsequently amended to include similar
claims by two additional plaintiffs. Defendant moved to
dismiss.
…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…trial. Ms. Maxwell’s responses to Plaintiff’s requests are
based on information currently known to her and are given without waiving Ms. Maxwell’s right
to use evidence of any subsequently discovered or identified facts, documents or
communications. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…specifically filed in the CVRA case
to oppose his efforts to intervene in that case and was unquestionably already in his possession.
Plaintiffs subsequently delivered a Bates stamped version of their original July 2015
document production to Dershowitz's counsel…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.22
17 pg
…when a party refuses to answer a
question during a deposition, the questioning party may subsequently move to compel disclosure
of the testimony that it sought. The court must determine the propriety of the deponent's
objection to answering the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.2
40 pg
…12. Identify any Health Care Provider from whom You received any treatment for any
physical, mental or emotional condition, that You suffered from subsequent to any
Alleged Defamation by Ghislaine Maxwell, including:
a. the Health Care Provider’s name, address…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…at the time, who
6 initially had told me that he would make everyone
7 available for an interview. And subsequent
8 conversations later, no one was available for
9 interview and everybody had an attorney, and I was
10…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…an opportunity to dispute them. Id. Although Ms. Giuffre
elaborated these false allegations in subsequent filings, eventually, the presiding judge in the
CRVA Action struck them as a sanction against the lawyers who had filed them. But the damage
to…
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