gov.uscourts.nysd.447706.988.1.pdf

Case 1:15-cv-07433-LAP Document 988-1 Filed 09/20/19 Page 1 of 5 Exhibit A  Case 1:15-cv-07433-LAP Document 988-1 Filed 09/20/19 Page 2 of 5 From: Sandra Perkins Sent: Thursday, April 27, 2017 4:12 PM To: '[email protected]' Cc: '[email protected]' Subject: RE: Giuffre v. Maxwell, Case No: 15-cv-07433-RWS Attachments: 2017.04.03 Defts Amended Objs to Ptfs Depo Desgs.pdf Follow Up Flag: Follow up Flag Status: Flagged Maya, See attached, in an abundance of caution, I just doubled check the docket and there appears to a late submission by Defendant [DE ] which doesn’t appear to be on the binder index. Attached is what I found in the unredacted e-mail distribution for this date. I believe you should now have everything you need. Please do not hesitate to contact me should you need anything further. Sandra From: [email protected] [mailto:[email protected]] Sent: Thursday, April 27, 2017 3:56 PM To: Sandra Perkins Cc: [email protected] Subject: RE: Giuffre v. Maxwell, Case No: 15-cv-07433-RWS That is very helpful, thank you. I just want to make sure that there is nothing MISSING from the Binder that the Judge needs to rule on. Maya Nuland Law Clerk to the Honorable Robert W. Sweet United States District Court for the Southern District of New York 500 Pearl Street, Suite 1940 New York, NY 10007-1312 (212) 805-0463 From: Sandra Perkins <[email protected]> To: "[email protected]" <[email protected]> Cc: "[email protected]" <[email protected]> Date: 04/27/2017 03:51 PM Subject: RE: Giuffre v. Maxwell, Case No: 15-cv-07433-RWS Maya, I hope this answers your question. There should be 10 items in the binder (which are both Plaintiff and Defendant submissions). However, the attached word versions relate to Plaintiff’s submissions and should correspond to the binder tabs 1, 3, 6, 7, 9 and 10. Please let me know if the binder has less than 10 items in it (or if there is anything missing) as it was assembled for us 1  Case 1:15-cv-07433-LAP Document 988-1 Filed 09/20/19 Page 3 of 5 in our NY office so I was unable to put eyes on it before it was delivered. Thank you and I apologize for any confusion, Sandra 01-13-2017 Plaintiff's Deposition Designations............................................................................... 1 01-27-2017 Plaintiff's Objections AND Cross Designations............................................................... 3 02-06-2017 Plaintiff's Supplemental Designations (Kellen/Marcinkova)............................................. 6 02-17-2017 Plaintiff's Objections to Defendant’s Counter Designations............................................ 7 03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9 03-28-2017 Notice of filing Typographical Errors........................................................................... 10 From: [email protected] [mailto:[email protected]] On Behalf Of [email protected] Sent: Thursday, April 27, 2017 3:40 PM To: Sandra Perkins Cc: [email protected] Subject: Re: Giuffre v. Maxwell, Case No: 15-cv-07433-RWS Thank you, Sandra. So which of these documents are what was in the binder? Since we received the binders on April 5, I understood that to contain the final versions of all of the deposition designations and objections to designations, incorporating all amendments, etc. Sandra Perkins <[email protected]> To "[email protected]" <[email protected]> 04/27/2017 01:37 PM cc "[email protected]" <[email protected]> Subject Giuffre v. Maxwell, Case No: 15-cv-07433-RWS To the honorable Judge Sweet, As a follow up to Maya Nuland’s phone call request today, please see the below list of what should in the designations binder submitted to the Court, along with the word versions of Plaintiff’s submissions (highlighted below). For the Court’s convenience, I have also included a word document for “Tab 2 - Defendant’s Deposition Designations (charted by BSF)” which was charted by BSF due to Defendant’s 1/13/17 submission being received in highlighted transcript form. Please feel free to contact me should you have any questions or need any additional information. DEPOSITION DESIGNATIONS, COUNTER DESIGNATIONS & OBJECTIONS 2  Case 1:15-cv-07433-LAP Document 988-1 Filed 09/20/19 Page 4 of 5 TAB 01-13-2017 Plaintiff's Deposition Designations............................................................................... 1 01-13-2017 Defendant’s Deposition Designations (Charted by BSF)................................................... 2 01-27-2017 Plaintiff's Objections AND Cross Designations............................................................... 3 01-27-2017 Defendant’s Objections to Plaintiff's Deposition Designations........................................ 4 02-03-2017 Defendant’s Counter-Designations to Plaintiff's Deposition Designations........................ 5 02-06-2017 Plaintiff's Supplemental Designations (Kellen/Marcinkova)............................................. 6 02-17-2017 Plaintiff's Objections to Defendant’s Counter Designations............................................ 7 02-17-2017 Defendant’s Objections to Plaintiff's Cross Designations................................................ 8 03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9 03-28-2017 Notice of filing Typographical Errors........................................................................... 10 Kindest Regards, Sandra Perkins Borger Paralegal 3  Case 1:15-cv-07433-LAP Document 988-1 Filed 09/20/19 Page 5 of 5 BOIES SCHILLER FLEXNER LLP 401 E. Las Olas Blvd. Suite 1200 Fort Lauderdale, FL, 33301 (t) +1 954 377 4219 (m) +1 954 356 0011 [email protected] www.bsfllp.com The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1] The information contained in this electronic message is confidential information intended only for the use of the named recipient(s) and may contain information that, among other protections, is the subject of attorney-client privilege, attorney work product or exempt from disclosure under applicable law. If the reader of this electronic message is not the named recipient, or the employee or agent responsible to deliver it to the named recipient, you are hereby notified that any dissemination, distribution, copying or other use of this communication is strictly prohibited and no privilege is waived. If you have received this communication in error, please immediately notify the sender by replying to this electronic message and then deleting this electronic message from your computer. [v.1] 4