gov.uscourts.nysd.447706.986.0.pdf

Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 1 of 60 Sigrid McCawley Telephone: (954) 356-0011 Email: [email protected] September 18, 2019 VIA ECF The Honorable Judge Loretta A. Preska District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-07433-LAP Dear Judge Preska: Plaintiff submits the following categories of documents pursuant to the Court’s Order of September 5, 2019. Dkt. 982. The parties met and conferred several times over the past two weeks, and were able to reach agreement with the exceptions of Categories 4 and 10 below. Plaintiff believes that all documents concerning trial deposition designations (including objections and counter-designations) fit comfortably within one category. Defendant requested that Category 4 be broken out into two separate categories: one for trial deposition designations, and another for counter-designations, trial objections, and counter-designations. Plaintiff includes as Category 10 “Motions re. depositions,” which Defendant’s list does not include. It is Plaintiff’s understanding from the meet and confer process that Defendant Maxwell’s submission may also include labeling certain docket entries as including information that was put forth in Defendant’s view for an “improper purpose.” Defendant did not challenge these submissions in the underlying action despite having the opportunity to do so, and it is Plaintiff’s position that Defendant cannot now inject these belated challenges, which are all unfounded in any event. While the parties generally agree as to the categories, there is disagreement as to which categories the individual docket entries listed below fall under. In addition, Plaintiff considers each document in question to be a judicial document. Categories Reflected in Docket Entries: 1. Motions to Compel and Related Motions for Protective Orders and Court Orders (“Motion to Compel”)  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 2 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |2 2. Motions in Limine re. Admissibility of Evidence and Related Orders (“Motion in Limine re. Admissibility of Evidence”) 3. Motions in Limine re. Expert Testimony and Related Orders (“Motion in Limine re. Expert”) 4. Trial Deposition Designations and Counter-Designations and Trial Objections and Counter Designations 5. Filings related to Third-Party Intervenors and Related Orders (“Pleadings re. Third-Party – Intervenors”) 6. Filings related to Third-Party – Other – and Related Orders (“Pleadings re. Third-Party – Other”) 7. Case Management Pleadings and Related Orders (“Case Management”) 8. Adverse Inference/Sanctions Motions/ Motions to Strike or Exclude Evidence 9. Trial Motions and Trial Submissions 10. Motions re. Depositions Date Filed DE Category Docket Text DECLARATION of Sigrid S. McCawley in Opposition re: 75 MOTION to Compel Responses Motion to Compel – Judicial to Defendant's First Set of Discovery Requests to 04/04/2016 79 Document Plaintiff filed by Virginia L. Giuffre. (Attachments: (Exhibit 4 “Restricted”) # 1 Exhibit Exhibit 1, # 2 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6) Motion to Compel REPLY MEMORANDUM OF LAW in Support re: 96 MOTION for Clarification of Court's Order and 04/25/2016 121 – Judicial Document For Forensic Examination. REDACTED filed by Redacted Virginia L. Giuffre.  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 3 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |3 DECLARATION of Sigrid McCawley in Support re: 96 MOTION for Clarification of Court's Order Motion to Compel and For Forensic Examination filed by Virginia L. 04/25/2016 122 – Judicial Document Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Redacted -Ex. 4, 7,8 Exhibit, # 4 Exhibit REDACTED, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED) Motion to Compel – Judicial REDACTED OPINION #106433 re: 33 MOTION Document to Compel Defendant Ghislaine Maxwell to 05/02/2016 135 Produce Documents Subject to Improper Claim of Redacted Privilege. Motion to Compel– Judicial Document RESPONSE re: 134 Order, Redacted filed by 05/04/2016 139 Virginia L. Giuffre. Redacted Motion to Compel DECLARATION of Sigrid McCawley re: 139 – Judicial Document Response, DECLARATION of Sigrid McCawley in 05/04/2016 140 Support filed by Virginia L. Giuffre. (Attachments: Redacted – Ex. 1 # 1 Exhibit Redacted, # 2 Exhibit, # 3 Exhibit) Motion to Compel NOTICE of In Camera Submission re: 134 Order. 05/04/2016 141 – Judicial Document Document filed by Virginia L. Giuffre. (In Camera Materials) Motion to Compel – Judicial MOTION to Compel Defendant Ghislaine Maxwell Document 05/05/2016 143 to Answer Deposition Questions Redacted filed by Virginia L. Giuffre. Redacted DECLARATION of Sigrid McCawley in Support Motion to Compel– Judicial re: 143 MOTION to Compel Defendant Ghislaine Maxwell to Answer Deposition Questions Redacted Document filed by Virginia L. Giuffre. (Attachments: # 1 05/05/2016 144 Exhibit Redacted, # 2 Exhibit Redacted, # 3 Redacted - Exs. 1, 2,4,5,6,7 Exhibit, # 4 Exhibit Redacted, # 5 Exhibit Redacted, # 6 Exhibit Redacted, # 7 Exhibit Redacted)  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 4 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |4 Motion to Compel – Judicial RESPONSE to Motion re: 143 MOTION to Document Compel Defendant Ghislaine Maxwell to Answer 05/10/2016 149 Deposition Questions Redacted filed by Ghislaine Redacted Maxwell. Motion to Compel DECLARATION of Jeffrey S. Pagliuca in Opposition re: 143 MOTION to Compel Defendant – Judicial Document 05/10/2016 150 Ghislaine Maxwell to Answer Deposition Questions Redacted filed by Ghislaine Maxwell. Redacted - Ex. A (Attachments: # 1 Exhibit A) Motion to Compel – Judicial REPLY MEMORANDUM OF LAW in Support re: Document 143 MOTION to Compel Defendant Ghislaine 05/11/2016 152 Maxwell to Answer Deposition Questions Redacted Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 143 MOTION to Compel Defendant Ghislaine Maxwell to Answer Deposition Questions Redacted Motion to Compel – Judicial filed by Virginia L. Giuffre. (Attachments: # 1 Document Exhibit Exhibit 1 Redacted, # 2 Exhibit Exhibit 2 05/11/2016 153 Part 1, # 3 Exhibit Exhibit 2 Part 2, # 4 Exhibit Redacted- Ex. 1 Exhibit 2 Part 3, # 5 Exhibit Exhibit 3 Part 1, # 6 Exhibit Exhibit 3 Part 2, # 7 Exhibit Exhibit 4, # 8 Exhibit Exhibit 5, # 9 Exhibit Exhibit 6, # 10 Exhibit Exhibit 7) Motion to Compel – Judicial Document MOTION to Compel Non-Privileged Documents 05/20/2016 155 filed by Ghislaine Maxwell. Redacted DECLARATION of Laura A. Menninger in Motion to Compel – Judicial Support re: 155 MOTION to Compel Non- Document Privileged Documents filed by Ghislaine Maxwell. 05/20/2016 156 (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit Redacted- Ex. E, J F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J) Motion regarding Deposition MOTION for Leave to Serve Three Deposition – Judicial Document 05/25/2016 160 Subpoenas by Means Other Than Personal Service Redacted filed by Virginia L. Giuffre. Redacted Motion regarding Deposition DECLARATION of Sigrid McCawley in Support re: 160 MOTION for Leave to Serve Three – Judicial Document 05/25/2016 161 Deposition Subpoenas by Means Other Than Personal Service Redacted. Document filed by Redacted- Ex. 2 Virginia L. Giuffre. (Attachments: # 1 Exhibit  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 5 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |5 Composite Exhibit 1, # 2 Exhibit Exhibit 2 Redacted, # 3 Exhibit Composite Exhibit 3, # 4 Exhibit Exhibit 4, # 5 Exhibit Exhibit 5, # 6 Exhibit Exhibit 6, # 7 Exhibit Exhibit 7, # 8 Exhibit Exhibit 8, # 9 Exhibit Composite Exhibit 9) Motion to Compel – Judicial MOTION to Compel all Attorney-Client Document Communications and Work Product Put At Issue by 05/26/2016 164 Plaintiff and Her Attorneys filed by Ghislaine Redacted Maxwell. (Menninger, Laura) DECLARATION of Laura A. Menninger in Support re: 164 MOTION to Compel all Attorney- Client Communications and Work Product Put At Motion to Compel – Judicial Issue by Plaintiff and Her Attorneys filed by Document Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 05/26/2016 165 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit Redacted-Ex. C,H, J, K H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q) Motion re Depositions – Judicial Document MOTION To Exceed Presumptive Ten Deposition 05/27/2016 172 Limit Redacted filed by Virginia L. Giuffre. Redacted DECLARATION of Sigrid McCawley in Support re: 172 MOTION To Exceed Presumptive Ten Motion re Depositions – Deposition Limit Redacted filed by Virginia L. Judicial Document Giuffre. (Attachments: # 1 Exhibit Exhibit 1, # 2 05/27/2016 173 Exhibit Exhibit 2, # 3 Exhibit Exhibit 3, # 4 Exhibit Redacted- Ex 5,6 Exhibit 4, # 5 Exhibit Exhibit 5 Redacted, # 6 Exhibit Exhibit 6 Redacted, # 7 Exhibit Exhibit 7 Part 1, # 8 Exhibit Exhibit 7 Part 2, # 9 Exhibit Exhibit 8, # 10 Exhibit Exhibit 9) Motion to Compel – Judicial RESPONSE in Opposition to Motion re: 155 Document 05/31/2016 179 MOTION to Compel Non-Privileged Documents filed by Virginia L. Giuffre. Redacted  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 6 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |6 DECLARATION of Meredith L. Schultz in Motion to Compel – Judicial Opposition re: 155 MOTION to Compel Non- Document Privileged Documents filed by Virginia L. Giuffre. 05/31/2016 180 (Attachments: # 1 Exhibit Redacted, # 2 Exhibit Redacted- Ex. 1,2,3,5,6 Redacted, # 3 Exhibit Redacted, # 4 Exhibit, # 5 Redacted, # 6 Redacted, # 7 Exhibit) Motion to Compel - Judicial RESPONSE in Opposition to Motion re: 164 MOTION to Compel all Attorney-Client Document 06/01/2016 184 Communications and Work Product Put At Issue by Plaintiff and Her Attorneys. . Document filed by Redacted Virginia L. Giuffre. DECLARATION of Sigrid S. McCawley in Opposition re: 181 LETTER MOTION to Seal Document 164 MOTION to Compel all Attorney- Motion to Compel – Client Communications and Work Product Put At Issue by Plaintiff and Her Attorneys, addressed to Judicial Document Judge Robert W. Sweet from Meredith Schultz dated 06/01/16 filed by Virginia L. Giuffre. 06/01/2016 185 (Attachments: # 1 Exhibit 1, # 2 Exhibit 2 Sealed, # 3 Exhibit 3 Sealed, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Redacted- Ex. 2,3,11,13, 14- Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 16 9, # 10 Exhibit 10, # 11 Exhibit 11 Sealed, # 12 Exhibit 12, # 13 Exhibit 13 Sealed, # 14 Exhibit 14 Sealed, # 15 Exhibit 15 Sealed, # 16 Exhibit 16 Sealed) Motion re Depositions – RESPONSE in Opposition to Motion re: 172 Judicial Document 06/06/2016 189 MOTION To Exceed Presumptive Ten Deposition Limit Redacted filed by Ghislaine Maxwell. Redacted Motion re Depositions – DECLARATION of Laura A. Menninger in Opposition re: 172 MOTION To Exceed 06/06/2016 190 Judicial Document Presumptive Ten Deposition Limit Redacted filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit Redacted- Ex. A A) Motion to Compel – Judicial REPLY to Response to Motion re: 155 MOTION to Document 06/06/2016 191 Compel Non-Privileged Documents, filed by Ghislaine Maxwell. Redacted  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 7 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |7 Motion to Compel – Judicial DECLARATION of Laura A. Menninger in Support re: 155 MOTION to Compel Non- Document 06/06/2016 192 Privileged Documents filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit K, # 2 Exhibit L, # 3 Redacted- Ex. K,L,M Exhibit M) DECLARATION of Laura A. Menninger in Motion to Compel – Judicial Support re: 164 MOTION to Compel all Attorney- Document Client Communications and Work Product Put At 06/06/2016 194 Issue by Plaintiff and Her Attorneys filed by Redacted- Ex. S Ghislaine Maxwell. (Attachments: # 1 Exhibit Q, # 2 Exhibit R, # 3 Exhibit S) RESPONSE in Support of Motion re: 202 LETTER Motion re Depositions – MOTION to Seal Document re Reply addressed to Judicial Document Judge Robert W. Sweet from Meredith Schultz 06/13/2016 203 dated 06/13/2016., 172 MOTION To Exceed Redacted Presumptive Ten Deposition Limit Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid S. McCawley in Support re: 202 LETTER MOTION to Seal Motion re Depositions – Document re Reply addressed to Judge Robert W. Sweet from Meredith Schultz dated 06/13/2016., Judicial Document 06/13/2016 204 172 MOTION To Exceed Presumptive Ten Deposition Limit Redacted. Document filed by Redacted- Ex. 1-3 Virginia L. Giuffre. (Attachments: # 1 Exhibit 1 (Sealed), # 2 Exhibit 2 (Sealed), # 3 Exhibit 3 (Sealed) Motion re Depositions – REPLY to Response to Motion re: 172 MOTION Judicial Document To Exceed Presumptive Ten Deposition Limit 06/14/2016 211 Redacted. CORRECTED filed by Virginia L. Redacted Giuffre. DECLARATION of Meredith L Schultz in Support Motion re Depositions – re: 172 MOTION To Exceed Presumptive Ten 06/14/2016 212 Judicial Document Deposition Limit Redacted filed by Virginia L. Redacted- Ex. 1-3 Giuffre. (Attachments: # 1 Exhibit SEALED, # 2 Exhibit SEALED, # 3 Exhibit SEALED) Motion re Depositions – REPLY to Response to Motion re: 172 MOTION Judicial Document 06/17/2016 224 To Exceed Presumptive Ten Deposition Limit Redacted. AMENDED filed by Virginia L. Giuffre. Redacted  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 8 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |8 Motion to Compel - Judicial RESPONSE in Opposition to Motion re: 199 Document 06/20/2016 228 MOTION for Extension of Time to Complete Depositions filed by Ghislaine Maxwell. Redacted DECLARATION of Laura A. Menninger in Motion to Compel - Judicial Opposition re: 199 MOTION for Extension of Time to Complete Depositions filed by Ghislaine Document Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit 06/20/2016 229 B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Redacted - Ex. A, B, D, J, K, Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit L I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N) Motion to Compel- Judicial Document MOTION to Reopen Deposition of Plaintiff 06/20/2016 230 Virginia Giuffre filed by Ghislaine Maxwell. Redacted Motion to Compel- Judicial MOTION for Sanctions 37(b) & (c) for Failure to Document 06/20/2016 231 Comply with Court Order and Failure to Comply with Rule 26(a) filed by Ghislaine Maxwell. Redacted DECLARATION of Laura A. Menninger in Support re: 231 MOTION for Sanctions 37(b) & (c) Motion to Compel- Judicial for Failure to Comply with Court Order and Failure to Comply with Rule 26(a) filed by Ghislaine Document 06/20/2016 232 Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Redacted - Ex. G, H, I, J, K Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N) DECLARATION of Laura A. Menninger in Support re: 230 MOTION to Reopen Deposition of Motion to Compel – Judicial Plaintiff Virginia Giuffre filed by Ghislaine Document Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit 06/21/2016 235 B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Redacted- Ex. D-K, M-N Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit K, # 11 Exhibit L, # 12 Exhibit M, # 13 Exhibit N)  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 9 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 Page |9 Motion to Compel– Judicial RESPONSE in Opposition to Motion re: 215 Document 06/22/2016 246 MOTION to Quash subpoena of Sharon Churcher filed by Ghislaine Maxwell. Redacted Motion to Compel - Judicial DECLARATION of Laura A. Menninger in Document Opposition re: 215 MOTION to Quash subpoena of 06/22/2016 247 Sharon Churcher filed by Ghislaine Maxwell. Redacted - Ex. B-C (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D) Motion to Compel - Judicial REPLY MEMORANDUM OF LAW in Support re: Document 199 MOTION for Extension of Time to Complete 06/22/2016 248 Depositions. REDACTED filed by Virginia L. Redacted Giuffre. DECLARATION of Sigrid McCawley in Support re: 199 MOTION for Extension of Time to Motion to Compel - Judicial Complete Depositions filed by Virginia L. Giuffre. Document (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, 06/22/2016 249 # 4 Exhibit REDACTED, # 5 Exhibit, # 6 Exhibit, Redacted- Exs. 4, 13-15 # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit REDACTED, # 14 Exhibit REDACTED, # 15 Exhibit REDACTED) Motion to Compel - Judicial RESPONSE in Opposition to Motion re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Document 06/28/2016 257 Comply with Court Order and Failure to Comply with Rule 26(a). REDACTED filed by Virginia L. Redacted Giuffre. DECLARATION of Sigrid McCawley in Opposition re: 231 MOTION for Sanctions 37(b) & Motion to Compel - Judicial (c) for Failure to Comply with Court Order and Document Failure to Comply with Rule 26(a) filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED, 06/28/2016 258 # 2 Exhibit REDACTED, # 3 Exhibit Redacted - Exs. 1-10 REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit REDACTED, # 10 Errata REDACTED)  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 10 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 P a g e | 10 Motion to Compel - Judicial RESPONSE in Opposition to Motion re: 230 MOTION to Reopen Deposition of Plaintiff 06/28/2016 259 Document Virginia Giuffre. REDACTED filed by Virginia L. Redacted Giuffre. Motion to Compel - Judicial DECLARATION of Sigrid McCawley in Opposition re: 230 MOTION to Reopen Deposition Document 06/28/2016 260 of Plaintiff Virginia Giuffre filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED, # Redacted – Exs. 1-2 2 Exhibit REDACTED) Motion to Compel- Judicial RESPONSE in Opposition to Motion re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Document 07/01/2016 261 Comply with Court Order and Failure to Comply with Rule 26(a). REDACTED-CORRECTED filed Redacted by Virginia L. Giuffre. Motion to Compel- Judicial REPLY MEMORANDUM OF LAW in Support re: Document 215 MOTION to Quash subpoena of Sharon 07/05/2016 263 Churcher filed by Sharon Churcher. (Feder, Eric) Redacted (07/05/2016) NOTICE of FILING REDACTED OPINION filed Redacted- DE 254-1: pp 9-10; 07/05/2016 264 by Virginia L. Giuffre. (Attachments: # 1 Text of 16-17 Proposed Order Proposed Redacted Opinion) Motion to Compel- Judicial REPLY to Response to Motion re: 230 MOTION to Document 07/08/2016 267 Reopen Deposition of Plaintiff Virginia Giuffre filed by Ghislaine Maxwell. Redacted Motion to Compel- Judicial DECLARATION of Laura A. Menninger in Support re: 230 MOTION to Reopen Deposition of Document 07/08/2016 268 Plaintiff Virginia Giuffre filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit O, # 2 Exhibit Redacted - Ex. O-P P) Motion to Compel- Judicial REPLY to Response to Motion re: 231 MOTION Document for Sanctions 37(b) & (c) for Failure to Comply 07/08/2016 269 with Court Order and Failure to Comply with Rule Redacted 26(a) filed by Ghislaine Maxwell.  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 11 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 P a g e | 11 DECLARATION of Laura A. Menninger in Motion to Compel- Judicial Support re: 231 MOTION for Sanctions 37(b) & (c) Document for Failure to Comply with Court Order and Failure 07/08/2016 270 to Comply with Rule 26(a) filed by Ghislaine Redacted Ex. O-R, T Maxwell. (Attachments: # 1 Exhibit O, # 2 Exhibit P, # 3 Exhibit Q, # 4 Exhibit R, # 5 Exhibit S, # 6 Exhibit T) LETTER MOTION for Leave to File Sur-Reply addressed to Judge Robert W. Sweet from Sigrid McCawley dated July 12, 2016 filed by Virginia L. Motion to Compel- Judicial Giuffre. (Attachments: # 1 Exhibit REDACTED Sur-Reply, # 2 Exhibit REDACTED Declaration, # Document 07/12/2016 272 3 Exhibit REDACTED Exhibit 1, # 4 Exhibit REDACTED Exhibit 2, # 5 Exhibit REDACTED Redacted - Ex. 1-8 Exhibit 3, # 6 Exhibit REDACTED Exhibit 4, # 7 Exhibit REDACTED Exhibit 5, # 8 Exhibit REDACTED Exhibit 6, # 9 Exhibit REDACTED Exhibit 7, # 10 Exhibit REDACTED Exhibit 8) Motion for Adverse Inference Judicial Document MOTION for Sanctions Motion for Adverse (Motion to Strike filed at DE 07/13/2016 279 Inference Instruction REDACTED filed by Virginia 288) L. Giuffre. Redacted Motion for Adverse Inference Judicial Document DECLARATION of Meredith Schultz in Support re: 279 MOTION for Sanctions Motion for Adverse (Motion to Strike filed at DE 07/13/2016 280 Inference Instruction REDACTED filed by Virginia 288) L. Giuffre. (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit) Redacted Ex. 1-2 LETTER RESPONSE in Opposition to Motion Motion for Adverse Inference addressed to Judge Robert W. Sweet from Meredith Judicial Document Schultz dated July 18, 2016 re: 288 LETTER MOTION for Discovery to Strike Plaintiff Virginia (Motion to Strike filed at DE 07/18/2016 290 Giuffre's Motion for an Adverse Inference 288) Instruction Pursuant to Rule 37(b), (e), and (f), Fed.R.Civ.P addressed to Judge Robert W. Sweet Redacted from Laura A. Menninger dated June 15, 201 REDACTED filed by Virginia L. Giuffre. Motion for Adverse Inference DECLARATION of Meredith Schultz in Opposition re: 288 LETTER MOTION for Judicial Document Discovery to Strike Plaintiff Virginia Giuffre's 07/18/2016 291 (Motion to Strike filed at DE Motion for an Adverse Inference Instruction 288) Pursuant to Rule 37(b), (e), and (f), Fed.R.Civ.P addressed to Judge Robert W. Sweet from Laura A.  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 12 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 P a g e | 12 Redacted - Ex. 1-3 Menninger dated June 15, 201 filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED) REPLY to Response to Motion re: 272 LETTER Motion to Compel- Judicial MOTION for Leave to File Sur-Reply addressed to Document Judge Robert W. Sweet from Sigrid McCawley 07/25/2016 303 dated July 12, 2016. Defendant's Sur Sur-Reply In Redacted Support of Motion for Rule 37(b) & (c) Sanctions filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Motion to Compel- Judicial Support re: 231 MOTION for Sanctions 37(b) & (c) Document for Failure to Comply with Court Order and Failure 07/25/2016 304 to Comply with Rule 26(a) filed by Ghislaine Redacted - Ex. U-X Maxwell. (Attachments: # 1 Exhibit U, # 2 Exhibit V, # 3 Exhibit W, # 4 Exhibit X) Motion re Depositions - MOTION for Extension of Time to Complete Judicial Document 07/25/2016 306 Discovery to Serve and Depose Ross Gow filed by Virginia L. Giuffre. Redacted DECLARATION of Meredith Schultz in Support Motion re Depositions re: 306 MOTION for Extension of Time to Complete Discovery to Serve and Depose Ross Judicial Document 07/25/2016 307 Gow filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Redacted - Ex. 7-8 Exhibit, # 6 Exhibit, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit) Motion for Sanctions- Party – DECLARATION of Meredith Schultz in Support re: 308 MOTION for Sanctions and finding Civil Other Contempt against Sarah Kellen for Ignoring 07/25/2016 309 Judicial Document Subpoena filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, Redacted # 4 Exhibit, # 5 Exhibit) Motion for Sanctions-Third DECLARATION of Meredith Schultz in Support re: 310 MOTION for Sanctions and for Finding of Party – Other Civil Contempt Against Nadia Marcinkova for 07/25/2016 311 Judicial Document Ignoring Subpoena filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, Redacted # 4 Exhibit, # 5 Exhibit) Motion to Compel- Judicial NOTICE of Supplemental Authority re: 257 07/29/2016 313 Document Response in Opposition to Motion filed by Virginia Redacted L. Giuffre. (Attachments: # 1 Exhibit REDACTED)  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 13 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 P a g e | 13 FILING ERROR – WRONG EVENT TYPE Motion to Compel- Judicial SELECTED FROM MENU – MOTION to Document Compel and Motion to Enforce the Court’s Order 07/29/2016 315 and Direct Defendant to Answer Deposition Redacted Questions filed by Virginia L. Giuffre. Modified on 8/10/2016. FILING ERROR - DEFICIENT DOCKET ENTRY - DECLARATION of Meredith Schultz in Support re: 315 MOTION to Compel and Motion to Motion to Compel- Judicial Enforce the Court's Order and Direct Defendant to Document Answer Deposition Questions filed by Virginia L. 07/29/2016 316 Giuffre. (Attachments: # 1 Exhibit REDACTED, # Redacted Ex. 1-8 2 Exhibit REDACTED, # 3 Exhibit REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED) Modified on 8/10/2016. Motion to Compel- Judicial MOTION Defendant's Submission Regarding Document "Search Terms" And Notice Of Compliance With 08/01/2016 320 Court Order Concerning Forensic Examination Of Redacted Devices filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 320 MOTION Defendant's Submission Motion to Compel- Judicial Regarding "Search Terms" And Notice Of Document Compliance With Court Order Concerning 08/01/2016 321 Forensic Examination Of Devices filed by Ghislaine Redacted - Ex. A-F Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F) Motion to Compel- Judicial MOTION for Protective Order and Motion for the Court to Direct Defendant to Disclose All Document 08/08/2016 335 Individuals to whom Defendant has Disseminated Confidential Information. Document filed by Redacted Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support Motion to Compel- Judicial re: 335 MOTION for Protective Order and Motion for the Court to Direct Defendant to Disclose All Document 08/08/2016 336 Individuals to whom Defendant has Disseminated Confidential Information filed by Virginia L. Redacted - Ex. 1-3 Giuffre. (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED) Motion for Adverse Inference MEMORANDUM OF LAW in Support re: 279 Judicial Document MOTION for Sanctions Motion for Adverse 08/08/2016 338 Inference Instruction REDACTED. Supplement Redacted Based on New Information filed by Virginia L.  Case 1:15-cv-07433-LAP Document 986 Filed 09/18/19 Page 14 of 60 The Honorable Judge Loretta A. Preska September 18, 2019 P a g e | 14 Giuffre. (Attachments: # 1 REDACTED DECLARATION, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit REDACTED, # 10 Exhibit REDACTED) Motion to Compel- Judicial RESPONSE in Opposition to Motion re: 315 Document MOTION to Compel and Motion to Enforce the 08/08/2016 339 Court's Order and Direct Defendant to Answer Redacted Deposition Questions filed by Ghislaine Maxwell. DECLARATION of Jeffrey S. Pagliuca in Opposition re: 315 MOTION to Compel and Motion to Compel- Judicial Motion to Enforce the Court's Order and Direct Document Defendant to Answer Deposition Questions filed by 08/08/2016 340 Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # Redacted - Ex. A, C-I 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I) Motion to Compel- Judicial MOTION to Compel Defendant to Produce Document Documents Subject to Improper Objection and 08/09/2016 345 Improper Claim of Privilege filed by Virginia L. Redacted Giuffre. DECLARATION of Meredith Schultz in Support re: 345 MOTION to Compel Defendant to Produce Motion to Compel- Judicial Documents Subject to Improper Objection and Document Improper Claim of Privilege filed by Virginia L. 08/09/2016 346 Giuffre. (Attachments: # 1 Exhibit REDACTED, # Redacted - Ex. 1-5 2 Exhibit REDACTED, # 3 Exhibit REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED) Motion to Strike - Judicial MOTION to Strike Document No. [338, and all Document supporting documents] to Plaintiff's Supplement to 08/10/2016 353 Motion for Adverse Inference Instruction Based on R