gov.uscourts.nysd.447706.991.1.pdf

Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 1 of 48 APPENDIX  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 2 of 48 Defendant Maxwell - Categories Reflected in Docket Entries: 1. Motions to Compel and Related Motions for Protective Orders and Court Orders (“Motion to Compel”) 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. Deposition Designations and Counter-Designations 5. Objections to Designations and Counter-Designations 6. Pleadings related to Third-Party Intervenors and Related Orders (“Pleadings re. Third-Party – Intervenors”) 7. Pleadings related to Third-Party – Other – and Related Orders (“Pleadings re. Third-Party – Other”) 8. Case Management Pleadings and Related Orders (“Case Management”) 9. Evidence and Motions filed for an Improper Purpose or Subject to a Motion to Strike or Exclude (“Improper Purpose”) Date Filed DE Category Docket Text DECLARATION of Sigrid S. McCawley in Opposition re: Motion to Compel 75 MOTION to Compel Responses to Defendant's First Set 04/04/2016 79 of Discovery Requests to Plaintiff filed by Virginia L. Exhibit 4 Restricted Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit) REPLY MEMORANDUM OF LAW in Support re: 96 04/25/2016 121 Motion to Compel MOTION for Clarification of Court's Order and For Forensic Examination. REDACTED filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 96 MOTION for Clarification of Court's Order and For Forensic Motion to Compel Examination filed by Virginia L. Giuffre. (Attachments: # 1 04/25/2016 122 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit REDACTED, # Improper Purpose Ex. 4, 7, 8 5 Exhibit, # 6 Exhibit, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED) REDACTED OPINION #106433 re: 33 MOTION to 05/02/2016 135 Motion to Compel Compel Defendant Ghislaine Maxwell to Produce Documents Subject to Improper Claim of Privilege. 1  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 3 of 48 RESPONSE re: 134 Order, Redacted filed by Virginia L. 05/04/2016 139 Motion to Compel Giuffre. DECLARATION of Sigrid McCawley re: 139 Response, Motion to Compel DECLARATION of Sigrid McCawley in Support filed by 05/04/2016 140 Virginia L. Giuffre. (Attachments: # 1 Exhibit Redacted, # 2 Improper Purpose Ex. 1 Exhibit, # 3 Exhibit) Motion to Compel NOTICE of In Camera Submission re: 134 Order,,. 05/04/2016 141 Improper Purpose - In Camera Document filed by Virginia L. Giuffre. Materials MOTION to Compel Defendant Ghislaine Maxwell to 05/05/2016 143 Motion to Compel Answer Deposition Questions Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 143 Motion to Compel MOTION to Compel Defendant Ghislaine Maxwell to Answer Deposition Questions Redacted filed by Virginia L. 05/05/2016 144 Giuffre. (Attachments: # 1 Exhibit Redacted, # 2 Exhibit Improper Purpose Exs. 1, 2, 4, 5, 6, 7 Redacted, # 3 Exhibit, # 4 Exhibit Redacted, # 5 Exhibit Redacted, # 6 Exhibit Redacted, # 7 Exhibit Redacted) RESPONSE to Motion re: 143 MOTION to Compel 05/10/2016 149 Motion to Compel Defendant Ghislaine Maxwell to Answer Deposition Questions Redacted filed by Ghislaine Maxwell. DECLARATION of Jeffrey S. Pagliuca in Opposition re: Motion to Compel 143 MOTION to Compel Defendant Ghislaine Maxwell to 05/10/2016 150 Answer Deposition Questions Redacted filed by Ghislaine Ex. A Maxwell. (Attachments: # 1 Exhibit A) REPLY MEMORANDUM OF LAW in Support re: 143 MOTION to Compel Defendant Ghislaine Maxwell to 05/11/2016 152 Motion to Compel Answer Deposition Questions Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 143 MOTION to Compel Defendant Ghislaine Maxwell to Motion to Compel Answer Deposition Questions Redacted filed by Virginia L. 05/11/2016 153 Giuffre. (Attachments: # 1 Exhibit 1 Redacted, # 2 Exhibit 2 Improper Purpose Ex. 1 Part 1, # 3 Exhibit 2 Part 2, # 4 Exhibit 2 Part 3, # 5 Exhibit 3 Part 1, # 6 Exhibit 3 Part 2, # 7 Exhibit 4, # 8 Exhibit 5, # 9 Exhibit 6, # 10 Exhibit 7) 2  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 4 of 48 MOTION to Compel Non-Privileged Documents filed by 05/20/2016 155 Motion to Compel Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 155 MOTION to Compel Non- Privileged Documents filed by Motion to Compel Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit 05/20/2016 156 B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E REDACTED, Redacted- Ex. E, J # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J REDACTED) MOTION for Leave to Serve Three Deposition Subpoenas 05/25/2016 160 Case Management by Means Other Than Personal Service Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 160 MOTION for Leave to Serve Three Deposition Subpoenas Case Management by Means Other Than Personal Service Redacted. Document 05/25/2016 161 filed by Virginia L. Giuffre. (Attachments: # 1 Composite Improper Purpose Ex. 2 Exhibit 1, # 2 Exhibit 2 Redacted, # 3 Composite Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Composite Exhibit 9) MOTION to Compel all Attorney-Client Communications 05/26/2016 164 Motion to Compel and Work Product Put At Issue by Plaintiff and Her Attorneys filed by Ghislaine Maxwell. (Menninger, Laura) DECLARATION of Laura A. Menninger in Support re: 164 MOTION to Compel all Attorney-Client Communications and Work Product Put At Issue by Plaintiff and Her Motion to Compel Attorneys filed by Ghislaine Maxwell. (Attachments: # 1 05/26/2016 165 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Ex. C, H, J, K Exhibit E, # 6 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, # 15 Exhibit O, # 16 Exhibit P, # 17 Exhibit Q) MOTION To Exceed Presumptive Ten Deposition Limit 05/27/2016 172 Case Management Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 172 MOTION To Exceed Presumptive Ten Deposition Limit Case Management Redacted filed by Virginia L. Giuffre. (Attachments: # 1 05/27/2016 173 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Improper Purpose Ex 5, 6 Exhibit 5 Redacted, # 6 Exhibit 6 Redacted, # 7 Exhibit 7 Part 1, # 8 Exhibit 7 Part 2, # 9 Exhibit 8, # 10 Exhibit 9) 3  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 5 of 48 RESPONSE in Opposition to Motion re: 155 MOTION to 05/31/2016 179 Motion to Compel Compel Non-Privileged Documents filed by Virginia L. Giuffre. Motion to Compel DECLARATION of Meredith L. Schultz in Opposition re: 155 MOTION to Compel Non-Privileged Documents filed 05/31/2016 180 by Virginia L. Giuffre. (Attachments: # 1 Exhibit Redacted, Ex. 1, 2, 3, 5, 6 # 2 Exhibit Redacted, # 3 Exhibit Redacted, # 4 Exhibit, # 5 Improper Purpose as to Ex. 6 Redacted, # 6 Redacted, # 7 Exhibit) RESPONSE in Opposition to Motion re: 164 MOTION to Compel all Attorney-Client Communications and Work 06/01/2016 184 Motion to Compel Product Put At Issue by Plaintiff and Her Attorneys . Document filed by Virginia L. Giuffre. DECLARATION of Sigrid S. McCawley in Opposition re: 181 LETTER MOTION to Seal Document 164 MOTION to Compel all Attorney-Client Communications and Work Motion to Compel Product Put At Issue by Plaintiff and Her Attorneys, addressed to Judge Robert W. Sweet from Meredith Schultz 06/01/2016 185 dated 06/01/16 filed by Virginia L. Giuffre. (Attachments: # Improper Purpose 1 Exhibit 1, # 2 Exhibit 2 Sealed, # 3 Exhibit 3 Sealed, # 4 Ex. 2, 3, 11, 13, 14-16 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 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) RESPONSE in Opposition to Motion re: 172 MOTION To 06/06/2016 189 Case Management Exceed Presumptive Ten Deposition Limit Redacted filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Opposition re: Case Management 172 MOTION To Exceed Presumptive Ten Deposition Limit 06/06/2016 190 Redacted filed by Ghislaine Maxwell. (Attachments: # 1 Ex. A Exhibit A) REPLY to Response to Motion re: 155 MOTION to Compel 06/06/2016 191 Motion to Compel Non-Privileged Documents, filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 155 Motion to Compel MOTION to Compel Non- Privileged Documents filed by 06/06/2016 192 Ghislaine Maxwell. (Attachments: # 1 Exhibit K, # 2 Exhibit Ex. K, L, M L, # 3 Exhibit M) 4  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 6 of 48 DECLARATION of Laura A. Menninger in Support re: 164 Motion to Compel MOTION to Compel all Attorney-Client Communications 06/06/2016 194 and Work Product Put At Issue by Plaintiff and Her Ex. S Attorneys filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit Q, # 2 Exhibit R, # 3 Exhibit S) RESPONSE in Support of Motion re: 202 LETTER MOTION to Seal Document re Reply addressed to Judge 06/13/2016 203 Case Management Robert W. Sweet from Meredith Schultz dated 06/13/2016., 172 MOTION To Exceed Presumptive Ten Deposition Limit Redacted filed by Virginia L. Giuffre. DECLARATION of Sigrid S. McCawley in Support re: 202 LETTER MOTION to Seal Document re Reply addressed to Case Management Judge Robert W. Sweet from Meredith Schultz dated 06/13/2016 204 06/13/2016., 172 MOTION To Exceed Presumptive Ten Improper Purpose Ex. 1-3 Deposition Limit Redacted. Document filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit 1 (Sealed), # 2 Exhibit 2 (Sealed), # 3 Exhibit 3 (Sealed) REPLY to Response to Motion re: 172 MOTION To Exceed 06/14/2016 211 Case Management Presumptive Ten Deposition Limit Redacted. CORRECTED filed by Virginia L. Giuffre. DECLARATION of Meredith L Schultz in Support re: 172 Case Management MOTION To Exceed Presumptive Ten Deposition Limit 06/14/2016 212 Redacted filed by Virginia L. Giuffre. (Attachments: # 1 Improper Purpose Ex. 1-3 Exhibit SEALED, # 2 Exhibit SEALED, # 3 Exhibit SEALED) REPLY to Response to Motion re: 172 MOTION To Exceed 06/17/2016 224 Case Management Presumptive Ten Deposition Limit Redacted. AMENDED filed by Virginia L. Giuffre. RESPONSE in Opposition to Motion re: 199 MOTION for 06/20/2016 228 Motion to Compel Extension of Time to Complete Depositions filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Opposition re: 199 MOTION for Extension of Time to Complete Motion to Compel Depositions filed by Ghislaine Maxwell. (Attachments: # 1 06/20/2016 229 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Ex. A, B, D, J, K, L Exhibit E, # 6 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) MOTION to Reopen Deposition of Plaintiff Virginia Giuffre 06/20/2016 230 Motion to Compel filed by Ghislaine Maxwell. 5  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 7 of 48 MOTION for Sanctions 37(b) & (c) for Failure to Comply 06/20/2016 231 Motion to Compel with Court Order and Failure to Comply with Rule 26(a) filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply with Court Order and Failure to Comply with Rule 26(a) Motion to Compel filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 2 06/20/2016 232 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 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 Plaintiff Virginia Giuffre Motion to Compel filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 06/21/2016 235 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 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) RESPONSE in Opposition to Motion re: 215 MOTION to 06/22/2016 246 Motion to Compel Quash subpoena of Sharon Churcher filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Opposition re: Motion to Compel 215 MOTION to Quash subpoena of Sharon Churcher filed 06/22/2016 247 by Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 2 Ex. B-C Exhibit B, # 3 Exhibit C, # 4 Exhibit D) REPLY MEMORANDUM OF LAW in Support re: 199 06/22/2016 248 Motion to Compel MOTION for Extension of Time to Complete Depositions. REDACTED filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 199 MOTION for Extension of Time to Complete Depositions Motion to Compel filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 06/22/2016 249 Exhibit, # 3 Exhibit, # 4 Exhibit REDACTED, # 5 Exhibit, # Improper Purpose - Ex. 4, 13-15 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit REDACTED, # 14 Exhibit REDACTED, # 15 Exhibit REDACTED) RESPONSE in Opposition to Motion re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply with Court 06/28/2016 257 Motion to Compel Order and Failure to Comply with Rule 26(a). REDACTED filed by Virginia L. Giuffre. 6  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 8 of 48 DECLARATION of Sigrid McCawley in Opposition re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply with Court Order and Failure to Comply with Rule 26(a) Motion to Compel filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit 06/28/2016 258 REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit Improper Purpose Ex. 1-10 REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit REDACTED, # 10 Errata REDACTED) RESPONSE in Opposition to Motion re: 230 MOTION to 06/28/2016 259 Motion to Compel Reopen Deposition of Plaintiff Virginia Giuffre. REDACTED filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Opposition re: 230 Motion to Compel MOTION to Reopen Deposition of Plaintiff Virginia Giuffre 06/28/2016 260 filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit Improper Purpose Ex. 1-2 REDACTED, # 2 Exhibit REDACTED) RESPONSE in Opposition to Motion re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply with Court 07/01/2016 261 Motion to Compel Order and Failure to Comply with Rule 26(a). REDACTED- CORRECTED filed by Virginia L. Giuffre. REPLY MEMORANDUM OF LAW in Support re: 215 07/05/2016 263 Motion to Compel MOTION to Quash subpoena of Sharon Churcher filed by Sharon Churcher. (Feder, Eric) (07/05/2016) NOTICE of FILING REDACTED OPINION filed by 07/05/2016 264 Motion to Compel Virginia L. Giuffre. (Attachments: # 1 Text of Proposed Order Proposed Redacted Opinion) REPLY to Response to Motion re: 230 MOTION to Reopen 07/08/2016 267 Motion to Compel Deposition of Plaintiff Virginia Giuffre filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 230 Motion to Compel MOTION to Reopen Deposition of Plaintiff Virginia Giuffre 07/08/2016 268 filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit O, # 2 Ex. O-P Exhibit P) 7  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 9 of 48 REPLY to Response to Motion re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply with Court 07/08/2016 269 Motion to Compel Order and Failure to Comply with Rule 26(a) filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 231 MOTION for Sanctions 37(b) & (c) for Failure to Comply Motion to Compel with Court Order and Failure to Comply with Rule 26(a) 07/08/2016 270 filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit O, # 2 Ex. O-R, T 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. Giuffre. (Attachments: # 1 Motion to Compel Exhibit REDACTED Sur-Reply, # 2 Exhibit REDACTED 07/12/2016 272 Declaration, # 3 Exhibit REDACTED Exhibit 1, # 4 Exhibit Improper Purpose Ex. 1-8 REDACTED Exhibit 2, # 5 Exhibit REDACTED 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) Improper Purpose MOTION for Sanctions Motion for Adverse Inference 07/13/2016 279 (Motion to Strike filed at DE 288) Instruction REDACTED filed by Virginia L. Giuffre. Improper Purpose DECLARATION of Meredith Schultz in Support re: 279 MOTION for Sanctions Motion for Adverse Inference (Motion to Strike filed at DE 288) 07/13/2016 280 Instruction REDACTED filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit Ex. 1-2 REDACTED, # 3 Exhibit) LETTER RESPONSE in Opposition to Motion addressed to Judge Robert W. Sweet from Meredith Schultz dated July 18, 2016 re: 288 LETTER MOTION for Discovery to Strike Improper Purpose Plaintiff Virginia Giuffre's Motion for an Adverse Inference 07/18/2016 290 (Motion to Strike filed at DE 288) Instruction Pursuant to Rule 37(b), (e), and (f), Fed.R.Civ.P addressed to Judge Robert W. Sweet from Laura A. Menninger dated June 15, 201 REDACTED filed by Virginia L. Giuffre. DECLARATION of Meredith Schultz in Opposition re: 288 LETTER MOTION for Discovery to Strike Plaintiff Virginia Improper Purpose Giuffre's Motion for an Adverse Inference Instruction (Motion to Strike filed at DE 288) Pursuant to Rule 37(b), (e), and (f), Fed.R.Civ.P addressed to 07/18/2016 291 Judge Robert W. Sweet from Laura A. Menninger dated June Ex. 1-3 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 for Leave to File Sur-Reply addressed to Judge Robert W. 07/25/2016 303 Motion to Compel Sweet from Sigrid McCawley dated July 12, 2016. Defendant's Sur Sur-Reply In Support of Motion for Rule 37(b) & (c) Sanctions filed by Ghislaine Maxwell. 8  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 10 of 48 DECLARATION of Laura A. Menninger in Support re: 231 Motion to Compel MOTION for Sanctions 37(b) & (c) for Failure to Comply 07/25/2016 304 with Court Order and Failure to Comply with Rule 26(a) Ex. U-X filed by Ghislaine Maxwell. (Attachments: # 1 Exhibit U, # 2 Exhibit V, # 3 Exhibit W, # 4 Exhibit X) MOTION for Extension of Time to Complete Discovery to 07/25/2016 306 Case Management Serve and Depose Ross Gow filed by Virginia L. Giuffre. DECLARATION of Meredith Schultz in Support re: 306 MOTION for Extension of Time to Complete Discovery to Case Management Serve and Depose Ross Gow filed by Virginia L. Giuffre. 07/25/2016 307 (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Ex. 7-8 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit) DECLARATION of Meredith Schultz in Support re: 308 MOTION for Sanctions and finding Civil Contempt against 07/25/2016 309 Pleadings re. Third-Party-Other Sarah Kellen for Ignoring Subpoena filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit) DECLARATION of Meredith Schultz in Support re: 310 MOTION for Sanctions and for Finding of Civil Contempt 07/25/2016 311 Against Nadia Marcinkova for Ignoring Subpoena filed by Pleadings re. Third-Party-Other Virginia L. Giuffre. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit) NOTICE of Supplemental Authority re: 257 Response in 07/29/2016 313 Motion to Compel Opposition to Motion filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED) FILING ERROR – WRONG EVENT TYPE SELECTED FROM MENU – MOTION to Compel and 07/29/2016 315 Motion to Compel Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition 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 Enforce the Court's Order and Direct Defendant to Answer Deposition Motion to Compel Questions filed by Virginia L. Giuffre. (Attachments: # 1 07/29/2016 316 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit Improper Purpose Ex. 1-8 REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED) Modified on 8/10/2016. 9  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 11 of 48 MOTION Defendant's Submission Regarding "Search Terms" And Notice Of Compliance With Court Order 08/01/2016 320 Motion to Compel Concerning Forensic Examination Of Devices filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 320 MOTION Defendant's Submission Regarding "Search Motion to Compel Terms" And Notice Of Compliance With Court Order 08/01/2016 321 Concerning Forensic Examination Of Devices filed by Ex. A-F Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F) MOTION for Protective Order and Motion for the Court to Direct Defendant to Disclose All Individuals to whom 08/08/2016 335 Motion to Compel Defendant has Disseminated Confidential Information. Document filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 335 MOTION for Protective Order and Motion for the Court to Motion to Compel Direct Defendant to Disclose All Individuals to whom 08/08/2016 336 Defendant has Disseminated Confidential Information filed Ex. 1-3 by Virginia L. Giuffre. (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED) MEMORANDUM OF LAW in Support re: 279 MOTION for Sanctions Motion for Adverse Inference Instruction REDACTED. Supplement Based on New Information filed by Motion to Compel / Improper Virginia L. Giuffre. (Attachments: # 1 REDACTED 08/08/2016 338 Purpose DECLARATION, # 2 Exhibit REDACTED, # 3 Exhibit (Motion to Strike filed at DE 353) REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit REDACTED, # 9 Exhibit REDACTED, # 10 Exhibit REDACTED) RESPONSE in Opposition to Motion re: 315 MOTION to Compel and Motion to Enforce the Court's Order and Direct 08/08/2016 339 Motion to Compel Defendant to Answer Deposition Questions filed by Ghislaine Maxwell. DECLARATION of Jeffrey S. Pagliuca in Opposition re: 315 MOTION to Compel and Motion to Enforce the Court's Motion to Compel Order and Direct Defendant to Answer Deposition 08/08/2016 340 Questions filed by Ghislaine Maxwell. (Attachments: # 1 Ex. A, C-I Exhibit A, # 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 Defendant to Produce Documents 08/09/2016 345 Motion to Compel Subject to Improper Objection and Improper Claim of Privilege filed by Virginia L. Giuffre. 10  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 12 of 48 DECLARATION of Meredith Schultz in Support re: 345 MOTION to Compel Defendant to Produce Documents Motion to Compel Subject to Improper Objection and Improper Claim of 08/09/2016 346 Privilege filed by Virginia L. Giuffre. (Attachments: # 1 Ex. 1-5 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED, # 4 Exhibit REDACTED, # 5 Exhibit REDACTED) MOTION to Strike Document No. [338, and all supporting documents] to Plaintiff's Supplement to Motion for Adverse 08/10/2016 353 Motion to Compel Inference Instruction Based on New Information filed by Ghislaine Maxwell. MOTION to Compel Responses to Defendant's Second Set of 08/10/2016 354 Motion to Compel Discovery Requests to Plaintiff, and for Sanctions filed by Ghislaine Maxwell. DECLARATION of Laura A. Menninger in Support re: 354 Motion to Compel MOTION to Compel Responses to Defendant's Second Set of 08/10/2016 355 Discovery Requests to Plaintiff, and for Sanctions filed by Ex. B Ghislaine Maxwell. (Attachments: # 1 Exhibit A, # 2 Exhibit B) MOTION to Direct DEFENDANT TO ANSWER 08/11/2016 356 Motion to Compel DEPOSITION QUESTIONS FILED UNDER SEAL filed by Virginia L. Giuffre. FILING ERROR - WRONG EVENT TYPE SELECTED FROM MENU - MOTION to Direct DEFENDANT TO ANSWER DEPOSITION QUESTIONS [SCHULTZ Motion to Compel DECLARATION ISO_DE 356_MOTION] filed by Virginia 08/11/2016 357 L. Giuffre. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2 Improper Purpose Ex. 1-8 (Sealed), # 3 Exhibit 3 (Sealed), # 4 Exhibit 4 (Sealed), # 5 Exhibit 5 (Sealed), # 6 Exhibit 6 (Sealed), # 7 Exhibit 7 (Sealed), # 8 Exhibit 8 (Sealed)) Modified on 8/12/2016 DECLARATION of Alan M. Dershowitz in Support re: 362 MOTION to Intervene. MOTION to Unseal Document or in Pleadings re. Third-Party the Alternative to Modify Protective Order. Document filed Intervenors by Alan M. Dershowitz. (Attachments: # 1 Exhibit A, # 2 08/11/2016 363 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Improper Purpose Ex. A-B, G, M 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) (Celli, Andrew) MEMORANDUM OF LAW in Support re: 362 MOTION to Pleadings Re. Third-Party Intervene. MOTION to Unseal Document or in the 08/11/2016 364 Alternative to Modify Protective Order filed by Alan M. Intervenors Dershowitz. (Celli, Andrew) 11  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 13 of 48 DECLARATION of Meredith Schultz in Support re: 357 MOTION to Direct DEFENDANT TO ANSWER DEPOSITION QUESTIONS [SCHULTZ DECLARATION ISO_DE 356_MOTION]., 315 MOTION to Compel and Motion to Compel Motion to Enforce the Court's Order and Direct Defendant to Answer Deposition Questions., 356 MOTION to Direct 08/12/2016 367 Improper Purpose - Ex. 1-8 DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL.. Document filed by Virginia L. Giuffre. (Attachments: # 1 Exhibit 1 (Sealed), # 2 Exhibit 2 (Sealed), # 3 Exhibit 3 (Sealed), # 4 Exhibit 4 (Sealed), # 5 Exhibit 5 (Sealed), # 6 Exhibit 6 (Sealed), # 7 Exhibit 7 (Sealed), # 8 Exhibit 8 (Sealed) REPLY MEMORANDUM OF LAW in Support re: 315 MOTION to Compel and Motion to Enforce the Court's Order and Direct Defendant to Answer Deposition Questions., 357 MOTION to Direct DEFENDANT TO Motion to Compel 08/12/2016 368 ANSWER DEPOSITION QUESTIONS [SCHULTZ DECLARATION ISO_DE 356_MOTION], 356 MOTION to Direct DEFENDANT TO ANSWER DEPOSITION QUESTIONS FILED UNDER SEAL.. Document filed by Virginia L. Giuffre. DECLARATION of Sigrid McCawley in Support re: 357 MOTION to Direct DEFENDANT TO ANSWER DEPOSITION QUESTIONS [SCHULTZ DECLARATION ISO_DE 356_MOTION] filed by Virginia L. Giuffre. Motion to Compel (Attachments: # 1 Exhibit REDACTED, # 2 Exhibit REDACTED, # 3 Exhibit REDACTED, # 4 Exhibit 08/12/2016 369 REDACTED, # 5 Exhibit REDACTED, # 6 Exhibit Ex. 1-16 REDACTED, # 7 Exhibit REDACTED, # 8 Exhibit Improper Purpose as to Ex. 2-16 REDACTED, # 9 Exhibit REDACTED, # 10 Exhibit REDACTED, # 11 Exhibit REDACTED, # 12 Exhibit REDACTED, # 13 Exhibit REDACTED, # 14 Exhibit REDACTED, # 15 Exhibit REDACTED, # 16 Exhibit REDACTED) Motion to Compel MOTION for Protective Order (REDACTED) Regarding 08/12/2016 370 Personal Financial Information filed by Ghislaine Maxwell. Ex. C (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C) DECLARATION of Laura A. Menninger in Support re: 370 Motion to Compel MOTION for Protective Order (REDACTED) Regarding 08/12/2016 371 Personal Financial Information filed by Ghislaine Maxwell. Ex. C (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C) RESPONSE in Opposition to Motion re: 354 MOTION to Motion to Compel Compel Responses to Defendant's Second Set of Discovery 08/17/2016 378 Requests to Plaintiff, and for Sanctions filed by Virginia L. Giuffre. 12  Case 1:15-cv-07433-LAP Document 991-1 Filed 09/25/19 Page 14 of 48 DECLARATION of Sigrid McCawley in Opposition re: 354 MOTION to Compel Responses to Defendant's Second Set of Motion to Compel Discovery Requests to Plaintiff, and for Sanctions filed by 08/17/2016 379 Virginia L. Giuffre. (Attachments: # 1 Exhibit Redacted, # 2 Ex.1, 3-6 Exhibit, # 3 Exhibit Redacted, # 4 Exhibit Redacted, # 5 Exhibit Redacted, # 6 Exhibit Redacted)