gov.uscourts.nysd.447706.124.0.pdf

Case 1:15-cv-07433-LAP Document 124 Filed 04/27/16 Page 1 of 3 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ...... ......................................... VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, 15-cv-07433-RWS Defendant. --------------------------------------------------X Unopposed Motion for Adjournment of Hearing on Plaintiff’s Motion for Forensic Examination Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. East 10th Avenue Denver, CO 80203 303.831.7364  Case 1:15-cv-07433-LAP Document 124 Filed 04/27/16 Page 2 of 3 Defendant Ghislaine Maxwell, through counsel, hereby respectfully requests that the Court adjourn the hearing on Plaintiff’s Motion for Forensic Examination (Doc. #96), scheduled for April 28, 2016, for the following reasons: Plaintiff filed her Motion for Clarification of Court’s Order and for Forensic Examination on April 13, 2016. On April 15, 2016, the Court scheduled a hearing on the portion of the motion concerning the forensic examination for April 28, 2016. Ms. Maxwell filed her response on April 21, 2016 (Doc. # 110). Plaintiff replied on April 25, 2016 (Doc. # 121). As represented to the Court on the record on April 21, 2016, counsel for Ms. Maxwell have previously scheduled court appearances and other professional matters that preclude their attendance on April 28, 2016. At the direction of the Court, counsel for the parties conferred about an adjournment of the hearing. Ms. McCawley indicated on the record that she did not oppose an adjournment. In Plaintiff’s Reply, she indicated that she would be willing to make an additional attempt to confer before rescheduling the hearing on the Motion. Reply at 3, n.3. Accordingly, the Parties believe that this issue may be resolved by conferral. It is anticipated that counsel for the parties will confer on May 2, 2016. Ms. Maxwell requests that the Court adjourn the hearing scheduled for April 28, 2016. If the parties are unable to reach a resolution of the issue they will notify the Court and request the matter be rescheduled for a hearing on the issue. 1  Case 1:15-cv-07433-LAP Document 124 Filed 04/27/16 Page 3 of 3 Dated: April 27, 2016 Respectfully submitted, /s/ Laura A. Menninger Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca HADDON, MORGAN AND FOREMAN, P.C. 150 East 10th Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell CERTIFICATE OF SERVICE I certify that on April 27, 2016, I electronically served this UNOPPOSED MOTION FOR ADJOURNMENT OF HEARING ON PLAINTIFF’S MOTION FOR FORENSIC EXAMINATION via ECF on the following: Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP 401 East Las Olas Boulevard, Ste. 1200 Ft. Lauderdale, FL 33301 [email protected] /s/ Nicole Simmons 2