gov.uscourts.nysd.447706.442.1.pdf

Case 1:15-cv-07433-LAP Document 442-1 Filed 09/21/16 Page 1 of 3 EXHIBIT 1  Case 1:15-cv-07433-LAP Document 442-1 Filed 09/21/16 Page 2 of 3 1 G4LMGIUC 1 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK 2 ------------------------------x 3 VIRGINIA L. GIUFFRE, 4 Plaintiff, 5 v. 15 Civ. 7433 (RWS) 6 GHISLAINE MAXWELL, 7 Defendant. 8 ------------------------------x New York, N.Y. 9 April 21, 2016 11:05 a.m. 10 Before: 11 HON. ROBERT W. SWEET, 12 District Judge 13 APPEARANCES 14 BOIES, SCHILLER & FLEXNER LLP 15 Attorneys for Plaintiff BY: SIGRID STONE McCAWLEY 16 -and- FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 17 BY: BRAD EDWARDS -and- 18 PAUL G. CASSELL 19 HADDON, MORGAN & FOREMAN Attorneys for Defendant 20 BY: LAURA A. MENNINGER JEFF PAGLUICA 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300  Case 1:15-cv-07433-LAP Document 442-1 Filed 09/21/16 Page 3 of 3 20 G4LMGIUC 1 The plaintiff has told me that they have now supplied 2 all the education and employment records that they have. I 3 think if there is any question about that, if the defense is 4 skeptical, I would ask the counsel for the plaintiffs to make 5 that statement on the record, not necessarily here, but by way 6 of a statement to the Court and principally to the defendant. 7 On the question of residences, that's, in my view, not 8 a contention interrogatory because of the nature of this case. 9 I think it's more like listing witnesses. So I would say that 10 the plaintiff should supply all residences. 11 The Dershowitz deposition will be produced under the 12 confidentiality provision. As I read what I've been given, 13 it's to be held in confidence and it will remain in confidence, 14 but it will be produced. 15 Yes, the tax returns should be produced. 15 years 16 seems like -- I see. Ok. 15 years. 17 The medical records of the period '99 to 2002 will be 18 produced and the plaintiff will indicate whether that 19 production is complete or, if it isn't complete, when it will 20 be complete. 21 As for the pre-'99 medical records, based on where we 22 are at the moment, I do not believe that those are relevant. 23 Because the damage issue relates, in my view, solely to the 24 defamation. If that changes in any way, I will revisit that 25 issue. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300