giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…In addition, Defendant set her deposition for Friday,
February 17, 2017 giving this witness less than two (2) weeks notice to make travel
arrangements from Europe. Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1101.0_1
1 pg
…entries to be reviewed for potential unsealing.” Dkt. 1096. Maxwell’s response, however,
included an unsolicited request for a “stay of the unsealing process for approximately three weeks,”
based on the vague assertion that, “[o]n Friday, August 7, 2020…
giuffre-maxwell
gov.uscourts.nysd.447706.434.0
1 pg
…2016, the Court issues a ruling on Cassell's motion to quash and
directed the parties to meet and confer within two weeks as to whether any redaction
were required in the Court's opinion before it was made public…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.1
21 pg
…as journalist
As set out in Churcher’s Declaration, she first met with Plaintiff in early 2011 and
conducted a weeks-long series of extensive interviews in person with Plaintiff, leading to a string
of publications in March of 2011…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…he, Laura Menninger and Ms. Maxwell were all traveling
on vacations in the weeks before and after the 4th of July holiday, that they would need additional time to comply
with the Court’s Order and provide the production. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…he, Laura Menninger and Ms. Maxwell were all traveling
on vacations in the weeks before and after the 4th of July holiday, that they would need additional time to comply
with the Court’s Order and provide the production. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…he, Laura Menninger and Ms. Maxwell were all traveling
on vacations in the weeks before and after the 4th of July holiday, that they would need additional time to comply
with the Court’s Order and provide the production. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…on June 1, 2016, weeks after her deposition and in the final month of the fact
discovery period, Plaintiff filed her “Third Revised” Rule 26 disclosures. She has expanded her
list of witnesses with relevant information from 69 specific witnesses…
giuffre-maxwell
gov.uscourts.nysd.447706.79.1
12 pg
…C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 79-1 Filed 04/04/16 Page 6 of 12
5
G3o5giuA phone conference
1 agreeable to the parties sometime in the week of April 18th.
2 Now…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.0_2
65 pg
…he, Laura Menninger and Ms. Maxwell were all traveling
on vacations in the weeks before and after the 4th of July holiday, that they would need additional time to comply
with the Court’s Order and provide the production. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.82.0_2
11 pg
…P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 82 Filed 04/07/16 Page 5 of 11 5
G3o5giuA phone conference
1 agreeable to the parties sometime in the week of April 18th.
2 Now…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…he, Laura Menninger and Ms. Maxwell were all traveling
on vacations in the weeks before and after the 4th of July holiday, that they would need additional time to comply
with the Court’s Order and provide the production. Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.13
35 pg
…Q. How long were you gone?
22 A. I think about three -- about
23 three weeks.
24 Q. So you met him before you
25 went to South Africa?
Highly Confidential
Page 182
1 HIGHLY CONFIDENTIAL AEO
2 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1124.0_3
2 pg
…As a preliminary matter, although Defendant did not propose a one-week extension of time
to object to the unsealing of the next set of Doe 1 and Doe 2 materials when conferring with
Plaintiff, Plaintiff does not oppose that…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.14
4 pg
…to negotiate the search terms for the search of our client’s
electronic devices. While Jeff raised many of these issues orally with Brad last week, I am including them in written form
so that there can be no dispute…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.6
4 pg
…You made the same request of us and we provided our proofs of service to
you earlier this week.
We are in the process of making travel arrangements for the depositions you noticed next week and scheduling around
other matters…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.16
6 pg
…reached:
1. I will endeavor to have my client gain access to an earthlink account that you believe is hers. Your basis for that
belief is a disk you produced last week, obtained pursuant to a FOIA request, that contained…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.17
6 pg
…reached:
1. I will endeavor to have my client gain access to an earthlink account that you believe is hers. Your basis for that
belief is a disk you produced last week, obtained pursuant to a FOIA request, that contained…
giuffre-maxwell
gov.uscourts.nysd.447706.438.0
1 pg
…moot and that Ms.
Giuffre will produce the settlement agreement to defense counsel immediately after the
endorsement of this letter. The Parties jointly request that the hearing scheduled for next week
be vacated.
Respectfully submitted,
…
giuffre-maxwell
gov.uscourts.nysd.447706.1123.0
2 pg
…Ms.
Maxwell also seeks a one-week extension of time to object to the unsealing of the Doe 1 and 2
materials at issue in this second round.
The Original Parties and the Court received a request for excerpts for…
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