gov.uscourts.nysd.447706.1090.36_1.pdf PDF
…Jason R." wrote: > > Hi Jenna, > > My suggestion is for you to do a Freedom of Information Act request (www.foia.gov) for the information you are looking for because I am…
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gov.uscourts.nysd.447706.354.0.pdf PDF
…this Motion. Based on the conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the Second Set of Discovery Requests. PRELIMINARY STATEMENT Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation…
gov.uscourts.nysd.447706.1328.20.pdf PDF
…After receiving Defendant’s production of the police reports pursuant to Rule 26 disclosures, Plaintiff wrote a letter requesting the Documents be designated Confidential. Counsel for Ms. Maxwell promptly responded that the documents are publicly available and therefore should not…
gov.uscourts.nysd.447706.1199.1_1.pdf PDF
…On May 20, 2016, counsel for Ms. Giuffre wrote Mr. Pagliuca a letter, explaining in detail both her good faith and statutory basis upon which she made her confidentiality designation, as various state statutes protect the confidentiality of these materials…
gov.uscourts.nysd.447706.276.0_1.pdf PDF
… That is Exhibit 1 to our brief 11 on this matter. 12 We wrote a letter to opposing counsel citing some 13 governing provisions of Microsoft's email policy that indicates 14 that due to inactivity they delete accounts after…
gov.uscourts.nysd.447706.1149.0.pdf PDF
…inducing parties to provide discovery in a contentious litigation.’” (DE 1113 at 5) Does 1 and 2 wrote this Court and expressed their desire to not have their names released. (DE 1125) Although they did not thereafter submit any objection…
gov.uscourts.nysd.447706.949.0.pdf PDF
…that sort of thing. My client and my reporter write 16 about those things all the time. She writes about children. 17 She writes about public officials whose information needs to be 18 redacted for safety purposes. 19 But the…
gov.uscourts.nysd.447706.63.0.pdf PDF
…and it was not until March 8, that Plaintiff’s counsel wrote a letter claiming that she would not be able to timely produce all responsive documents. In that letter, she expressed her desire to produce documents on a “rolling…
gov.uscourts.nysd.447706.849.0.pdf PDF
…you know, alluding to that point, 18 your Honor, there are so many redactions, it's unclear who 19 wrote the report, but more importantly, the content of the 20 report is so heavily redacted, we don't know what…
gov.uscourts.nysd.447706.847.0.pdf PDF
…you know, alluding to that point, 18 your Honor, there are so many redactions, it's unclear who 19 wrote the report, but more importantly, the content of the 20 report is so heavily redacted, we don't know what…
gov.uscourts.nysd.447706.993.0.pdf PDF
…Maxwell’s counsel, Laura Meninger, wrote Giuffre’s counsel: “I propose that both sides aim to submit any changes [to the designations], as well as one set of depo transcripts marked with both sides designations and objections, by March 24th…
gov.uscourts.nysd.447706.1199.6_1.pdf PDF
…After receiving Defendant’s production of the police reports pursuant to Rule 26 disclosures, Plaintiff wrote a letter requesting the Documents be designated Confidential. Counsel for Ms. Maxwell promptly responded that the documents are publicly available and therefore should not…
gov.uscourts.nysd.447706.983.0.pdf PDF
…we made to the Second Circuit when we handled it 7 at the summary judgement sealing of materials. 8 THE COURT: How do you people intend to address the 9 non-party claim that Mr. Lewin wrote about? 10 MS…
gov.uscourts.nysd.447706.1188.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1080.0.pdf PDF
…7433-LAP Dear Judge Preska, We represent Plaintiff Virginia Giuffre in this matter and write in response to the Court’s order directing the parties to prepare for unsealing the documents listed in Exhibit A to Plaintiff’s Opposition to…
gov.uscourts.nysd.447706.1105.0.pdf PDF
…York, NY 10007-1312 Re: Giuffre v. Maxwell, 15 Civ. 7433 (LAP) (“Maxwell”) Dear Judge Preska: We write on behalf of a non-party, John Doe, for two purposes: First, pursuant to the Court’s direction in its August 4…
gov.uscourts.nysd.447706.1154.0_5.pdf PDF
…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…
gov.uscourts.nysd.447706.1099.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1128.0_4.pdf PDF
…NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, We represent Plaintiff Virginia Giuffre in this matter and write to confirm that, pursuant to the Court’s orders dated July 28, 29, and 30…
gov.uscourts.nysd.447706.1250.0.pdf PDF
…Re: Giuffre v. Maxwell, 15 Civ. 7433 (LAP) Dear Judge Preska: We write respectfully on behalf of non-party John Doe in response to the Memorandum of Intervenors Julie Brown and The Miami Herald Media Co. (collectively, “Intervenors”). See DE…