…confer, (2) stated that any discussion of their collection procedures inappropriate, and (3) wrote that “[w]e do not believe we have an obligation to describe for your [sic] our document search methods.” See McCawley Decl. at Exhibit 1, April…
…at 8:00 PM, Brad Edwards wrote: Just to be clear, I specifically did not confer with anyone about this issue. A few weeks ago Jeff told me they had not received search terms and if I…
…10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, The Original Parties write in response to the Court’s December 14, 2020, order directing them to confer about a proposed next set of docket entries…
…15 Civ. 7433 (LAP) Dear Judge Preska: On behalf of Ghislaine Maxwell, we write in response to Plaintiff’s letters to the Court dated November 10, 2020 (DE 1143) and November 16, 2020 (DE 1153) concerning various issues surrounding the…
…v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes in response to Defendant’s letter dated September 30, 2020, seeking clarification from the Court regarding Doe 1 and Doe 2’s communication to the Court. ECF…
…Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes pursuant to the Court’s August 3, 2020 order directing the parties to confer and report suggestions for streamlining the unsealing process and a proposed next set of docket…
…USVI’s motion should be denied principally for the reasons set forth in the defendant’s submission, see DE 1118; we write here only to emphasize three points. A. No Intervention Is Necessary, As the Second Circuit Has Already Ordered …
…1312 Re: Giuffre v. Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We write respectfully on behalf of non-party John Doe in response to a letter submitted by the parties in Giuffre v. Dershowitz, 19 Civ. 3377 (LAP) (“Dershowitz…
…10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, The Parties write in response to the Court’s July 1, 2021, direction that the Parties meet and confer and propose to the Court ways to…
…behalf of Ms. Maxwell, we write to seek clarification from the Court regarding the Updated Protocol (Doc. # 1108) as it applies to Doe 1 and Doe 2’s recent communication and the related deadlines for objecting and responding. After conferral…
…competing proposals for streamlining the unsealing process established by the Order and Protocol for Unsealing Decided Motions. See DE 1224. We write to express our views regarding the parties’ respective submissions, as well as that offered by the Miami Herald…
…Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes concerning the Court’s August 26 and 27, 2020, orders regarding the next steps in the Court’s individualized review of the sealed materials, and deadlines…
…Preska: On behalf of non-party, John Doe, we write in response to Plaintiff’s letter of August 5, 2021, see DE 1227. Our letter of August 4, 2021 suggested several proposals to help expedite the continued implementation of the…
…10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, The Parties write in response to the Court’s September 28, 2021, order directing the Parties to “submit a revised version of the protocol” and “a…
…July 19, 2016 1:33 PM To: Meredith Schultz Subject: RE: Giuffre - Conferral regarding search terms Meredith: I write to confirm our oral conferral. Please let me know if you disagree with the following or if there is some other…