gov.uscourts.nysd.447706.648.0.pdf

Case 1:15-cv-07433-RWS Document 648 Filed 02/27/17 Page 1 of 4 Case 1:15-cv-07433-RWS Document 643 Filed 02/23/17 Page 1of4 VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------)( AMENDED SECOND PROPOSED DISCOVERY AND CASE MANAGEMENT DEADLINES AND REQUEST TO MODIFY PRETRIAL SCHEDULING ORDER  Case 1:15-cv-07433-RWS Document 648 Filed 02/27/17 Page 2 of 4 Case 1:15-cv-07433-RWS Document 643 Filed 02/23/17 Page 2 of 4 The Parties, through their respective counsel, propose the following case management deadlines and request that the Court enter an order modifying its Order of October 3, 2016, ECF #455 for the following reasons: Subsequent to the hearing on February 16, 2017 the parties have conferred extensively about the viability of the existing case management deadlines. The parties agree that the previous deadlines are no longer tenable. Accordingly, subject to the Court' s approval and availability the parties propose the following schedule: The jury trial scheduled for March 13, 2017 is rescheduled to begin on May 15, 2017 and is anticipated to last four weeks; Motions in Limine/other motions shall be filed by March 3, 2017; Final Exhibit lists shall be exchanged by the parties no later than April 3, 2017 and submitted to the Court by April 15, 2017; The Revised Joint Pre-trial Order shall be submitted by April 15, 2017; Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by April 24, 2017; Proposed jury questions shall be submitted by May 1, 2017. The parties suggest that the Court may wish to consider scheduling hearings on outstanding issues, as necessary, as follows: March 9, 2017, hearing on Plaintiff Giuffre' s Motion to Present Testimony from Jeffrey Epstein for Purposes of Obtaining an Adverse Inference, ECF #608, hearing on Plaintiff's Motion to Compel all Work Product and Attorney Client Communications with Philip Barden, ECF #637, hearing on outstanding motions including Motion to Quash Edwards Subpoena, filed in the Southern District of Florida on June 13, 2016 under case number 16-mc-61262, and March 23 , 2017, hearing on 702 Motions ECF #520, 522, 524, 526, 528, 530, 533, 535 and motions in limine. April 6, 2017, hearing on objections to deposition designations. May 4, 2107, Pre-trial Conference to address any outstanding issues including confidentiality. WHEREFORE, the parties request that the Court adopt the proposed schedule and modify the Court' s Order of October 3, 2016 to reflect the above deadlines. 1  Case 1:15-cv-07433-RWS Document 648 Filed 02/27/17 Page 3 of 4 Case 1:15-cv-07433-RWS Document 643 Filed 02/23/17 Page 3 of 4 Dated: February 23 , 2017 Respectfully submitted, Isl Bradley J Edwards Isl Jeffrey S. Pagliuca Bradley J. Edwards Laura A. Menninger (LM-1374) FARMER, JAFFE, WEIS SING, EDWARDS, Jeffrey S. Pagliuca (pro hac vice) FISTOS & LEHRMAN, P.L. Ty Gee (pro hac vice) 425 North Andrews Ave., Ste. 2 HADDON, MORGAN AND FOREMAN, P.C. Ft. Lauderdale, FL 33301 150 East 101h Avenue [email protected] Denver, CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorney for Virginia Giuffre Attorneys for Ghislaine Maxwell 2  Case 1:15-cv-07433-RWS Document 648 Filed 02/27/17 Page 4 of 4 Case 1:15-cv-07433-RWS Document 643 Filed 02/23/17 Page 4 of 4 CERTIFICATE OF SERVICE I certify that on February 23 , 2017, I electronically served this AMENDED SECOND PROPOSED DISCOVERY AND CASE MANAGEMENT DEADLINES AND REQUEST TO MODIFY PRETRIAL SCHEDULING ORDER via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] J. Stanley Pottinger Bradley J. Edwards 49 Twin Lakes Rd. FARMER, JAFFE, WEISSING, EDWARDS , South Salem, NY l 0590 FISTOS & LEHRMAN, P.L. [email protected] 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] Isl Nicole Simmons Nicole Simmons 3