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gov.uscourts.nysd.447706.35.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.35.0 31 pg
V14 P18 P17 V11 D6

…statements through her agent Ross Gow. The offending defamatory statement was issued on January 3, 2015. As demonstrated by the timeline, discussed above, any documents that Maxwell has from the period from 1999 to the present are highly relevant. Ms…

gov.uscourts.nysd.447706.43.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.43.0 15 pg
V11 P17 V14 D6 P18

…but is simply refusing to produce the documents. Therefore, based upon the timeline set forth in the moving papers, Ms. Giuffre respectfully requests that this Court direct Defendant to produce responsive documents from 1999 to the present. Defendant argues that…

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