gov.uscourts.nysd.447706.58.0.pdf

Case 1:15-cv-07433-LAP Document 58 Filed 03/15/16 Page 1 of 2 United States District Court Southern District of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. _________________________/ NOTICE OF PLAINTIFF’S MOTION FOR LEAVE TO SERVE ROLLING PRODUCTION AND PRIVILEGE LOG Plaintiff, Ms. Giuffre, hereby gives notice, pursuant to Local Civil Rule 7.1, of her Motion for Leave to Serve Rolling Production and Privilege Log pursuant to Local Civil Rule 26.2. Dated: March 15, 2016. Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP By: /s/ Sigrid McCawley Sigrid McCawley (Pro Hac Vice) Boies, Schiller & Flexner LLP 401 E. Las Olas Blvd., Suite 1200 Ft. Lauderdale, FL 33301 (954) 356-0011 David Boies Boies, Schiller & Flexner LLP 333 Main Street Armonk, NY 10504 Ellen Brockman Boies, Schiller & Flexner LLP 575 Lexington Ave New York, New York 10022 (212) 446-2300 1  Case 1:15-cv-07433-LAP Document 58 Filed 03/15/16 Page 2 of 2 CERTIFICATE OF GOOD FAITH The undersigned hereby certifies that Counsel for Plaintiff conferred with Defendant’s Counsel by sending a detailed letter detailing the request, and counsel for both parties have followed up by placing two phone calls, but have been unable to speak directly due to conflicting schedules, and therefore were unable to resolve the issue. Counsel for Ms. Giuffre files this Motion in an abundance of caution in the even that counsel for the parties cannot complete their conferral process by tomorrow, March 16, 2016, when the Responses and Objections are due. The undersigned counsel will withdraw the instant motion should counsel for the parties reach an agreement prior to adjudication. _/s/ Sigrid S. McCawley______ Sigrid S. McCawley CERTIFICATE OF SERVICE I HEREBY CERTIFY that on March 15, 2016, I electronically filed the foregoing document with the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served this day on the individuals identified below via transmission of Notices of Electronic Filing generated by CM/ECF. Laura A. Menninger, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: (303) 831-7364 Fax: (303) 832-2628 Email: [email protected] _/s/ Sigrid S. McCawley______ Sigrid S. McCawley 2