giuffre-maxwell
gov.uscourts.nysd.447706.1325.13
2 pg
…are not the intended recipient, do not read, use, disseminate, distribute or copy this message or
attachments. If you have received this message in error, please notify the sender immediately and delete this message
together with any attachments.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.5_2
30 pg
… Dr. Donahue ............................................................................................................ 9
B. Dr. Hayek ................................................................................................................ 9
C. Dr. Kutikoff, Wellington Imaging Associates (“Wel…
giuffre-maxwell
gov.uscourts.nysd.447706.1298.0
1 pg
…2022 (Dkt. 1297) asking the parties
to jointly prepare and file a chart concerning the remaining non-objecting Does.
The parties have been working together to prepare the chart for filing. The number of non-
objecting Does and pleadings at…
giuffre-maxwell
gov.uscourts.nysd.447706.1188.0
3 pg
…the objections
of Does 55, 56, 93, and 151 together. This would be efficient because the names of Does 55, 56,
and 93 only appear in motions that Doe 151’s name also appears in, so the parties and the…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…Working off the Non-Party’s list, I have been looking at the list that has the Doe I, Doe
II identifiers down the right-hand side, and our proposal is that we begin with Doe I and II
together . . . .”)…
giuffre-maxwell
gov.uscourts.nysd.447706.1258.0
3 pg
…heard, together with such other and further relief as this Court deems just and proper.
1
Case 1:15-cv-07433-LAP Document 1258 Filed 07/28/22 Page 2 of 3
PLEASE TAKE NOTICE that opposition papers, if…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.26
5 pg
…at the house maybe a handful of days, again.
7 Q. I would like to direct you to, you
8 have it pulled together now, it's page 39,
9 Bates stamped Giuffre 00040?
10 A. Can you repeat that…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.21
11 pg
…All the best
David Brown
Reporter
The Times
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giuffre-maxwell
gov.uscourts.nysd.447706.1200.17
5 pg
…time, had met with
19 and went shopping with her at the Palm Beach
20 Mall, where they purchased items from
21 Victoria's Secrets.
22 After spending the day together, they went
23 over to the Palm Beach house…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.22
5 pg
…During that time,
- had met with
and went shopping with her at the Palm Beach
Mall, where they purchased items from
-
21 Victoria's Secrets.
22 After spending the day together,…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…included the name “max*” well aware that our client’s surname, and that of all of her paternal family members,
will begin with those three letters together. Your search terms thus are likely to yield every single email sent or…
giuffre-maxwell
gov.uscourts.nysd.447706.1087.0
4 pg
…today.” (Id. at 2.) On top of this--and despite the
Court’s instruction that the parties work together to ensure that
the materials were properly redacted by the appointed time--Ms.
Maxwell apparently has not provided to Ms. Giuffre…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Maxwell is submitting her
Response to the Motion for Protective Order together with her Motion to Compel.
2
In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic…
giuffre-maxwell
gov.uscourts.nysd.447706.550.0
3 pg
…2017, or as soon thereafter
as counsel may be heard, together with such other and further relief as this Court deems just and
proper.
1
PLEASE TAKE NOTICE that opposition papers, if any, shall be served in accordance with…
giuffre-maxwell
gov.uscourts.nysd.447706.1321.0
2 pg
…on social media. Without this list,
Intervenors and the public are puzzling together the Court’s ruling with each of the unsealed
documents to match the identities of each of the third parties with the Court’s ruling. Many of…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…calendar with the caveat that dates
may shift if witnesses make change requests but we are doing our best to group locations together where possible.
Again - this is not final as I noted I believe you had some dates you…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
… Dr. Donahue ............................................................................................................ 9
B. Dr. Hayek ................................................................................................................ 9
C. Dr. Kutikoff, Wellington Imaging Associates (“Wel…
giuffre-maxwell
gov.uscourts.nysd.447706.362.0
2 pg
…documents previously filed with the Court,
or in the alternative for an Order modifying the Protective Order previously entered by the Court,
together with such other and further relief as this Court deems just and proper.
PLEASE TAKE NOTICE that…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…13 MR. GUIRGUIS: No, you do
14 need to answer this.
15 A. Okay. We've been together
16 almost a year.
17 Q. And what is your current
18 occupation?
19 A. I'm a writer.
20 Q. And…
giuffre-maxwell
gov.uscourts.nysd.447706.288.2
3 pg
…i.e.,divorced from the
accom panyingsurnam esorfirstnam es. You haveincluded thenam e“ m ax*” w ellaw arethatour
client’ssurnam e,and thatofallofherpaternalfam ily m em bers,w illbeginw iththosethreeletters
together. Yoursearchterm sthusarelikely toyield every singleem ailsentorreceived by ourclient,or…
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