giuffre-maxwell
gov.uscourts.nysd.447706.1267.0
2 pg
…firm of Holland & Knight. Co-counsel of record for
Intervenors Christine Walz and Cynthia Gierhart of Holland & Knight will continue to represent
Intervenors in this action. The withdrawal will not cause prejudice to any party; accordingly, the
undersigned respectfully requests…
giuffre-maxwell
gov.uscourts.nysd.447706.710.0
1 pg
…Maxwell,
Case No.: 15-cv-07433-RWS
Dear Judge Sweet:
I write to request withdrawal of DE 707 and DE 708 (for a scrivener’s error) and
submit the following corrected letter motion.
As a follow up to the March…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…a confidential settlement and mutual
release between themselves and Dershowitz, then go on to state:
“
In the event that the noticed withdrawal is determined to be subject to Court
approval, the Plaintiffs would show in support of this notice that…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.11
5 pg
…12 (filed under seal).
14. Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of
Summary Judgment Motion.
15. Attached hereto as Exhibit 13 is a true and correct copy of Affidavit of Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.185.0
5 pg
… Attached hereto as Exhibit 12 is a true and correct copy of Notice of Withdrawal of
Summary Judgment Motion.
15.
Case 1:15-cv-07433-LAP Document 185 Filed 06/01/16 Page 3 of 5
16.
17.
18…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.16
16 pg
…to Laura Menninger on May 5,
2017, Ms. Giuffre purported to give notice of her “withdrawal of her confidentiality designation
of Ms. Ransome’s deposition transcript in its entirety.” We understand Ms. Maxwell will move
to oppose this de-designation…
giuffre-maxwell
gov.uscourts.nysd.447706.2.0
2 pg
…REAPPORTIONMENT
I I 130 MILLE R ACT LIA BI LITY I I 365 PERSONAL INJURY 2 1 use 86t I ) 423 WITHDRAWAL I ] 410 ANTITRUST
f l 140 NEGOTIABLE [)
giuffre-maxwell
gov.uscourts.nysd.447706.1320.18
40 pg
…defamation case contained in the then-pending summary judgment motion. McCawley Decl.,
Exhibit 12, Notice of Withdrawal of Summary Judgment Motion. As explained in the notice of
withdrawal of this motion, “the withdrawal of the referenced filings is not intended…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.17
11 pg
…Q Okay. There is an entry date for
5 Ms. Roberts at Survivors Charter School of
6 10/12/2001, and a withdrawal on 3/7 of '02. Do you
7 see that?
8 A I mean, it's this…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.14_2
40 pg
…then-pending summaiy judgment motion. Mccawley Deel. ,
Exhibit 12, Notice of Withdrawal of Summa1y Judgment Motion. As explained in the notice of
withdrawal of this motion, "the withdrawal of the referenced filings is not intended to be, and
should not…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…Act
D 120 Maiine D 310 Airplane 0 365 Personal htju,y • of Property 21 USC 88 I 0 423 Withdrawal □ 376 Qui Tam (31 USC
D 130 Miller Act 0 315 Airplane Product Product Liability D 690 Other…
giuffre-maxwell
1320-18
40 pg
…defamation case contained in the then-pending summary judgment motion. McCawley Decl.,
Exhibit 12, Notice of Withdrawal of Summary Judgment Motion. As explained in the notice of
withdrawal of this motion, “the withdrawal of the referenced filings is not intended…
giuffre-maxwell
gov.uscourts.nysd.447706.408.0
13 pg
…defamation case contained in the then-
pending summary judgment motion and Dershowitz withdrew his allegations of unethical
conduct, as reflected in the Notice of Withdrawal of Motion for Partial Summary Judgment
attached hereto as Sealed Exhibit 4.
27. As Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.363.0
18 pg
…that stated
that Ms. Giuffre “reaffirms” her allegations against me, and that their mistake in filing those
allegations in the CVRA Action was merely “tactical.” See Ex. J (Notice of Withdrawal). David
Boies, another of Ms. Giuffre’s attorneys in…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.1
13 pg
…defamation case contained in the then-
pending summary judgment motion and Dershowitz withdrew his allegations of unethical
conduct, as reflected in the Notice of Withdrawal of Motion for Partial Summary Judgment
attached hereto as Sealed Exhibit 4.
27. As Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.9
18 pg
…that stated
that Ms. Giuffre “reaffirms” her allegations against me, and that their mistake in filing those
allegations in the CVRA Action was merely “tactical.” See Ex. J (Notice of Withdrawal). David
Boies, another of Ms. Giuffre’s attorneys in…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.45
13 pg
…defamation case contained in the then-
pending summary judgment motion and Dershowitz withdrew his allegations of unethical
conduct, as reflected in the Notice of Withdrawal of Motion for Partial Summary Judgment
attached hereto as Sealed Exhibit 4.
27. As Mr…
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