Giuffre v. Dershowitz
| VIRGINIA L. GIUFFRE |
| Alan M. Dershowitz and Alan Dershowitz |
| Boies Schiller Flexner LLP, Leslie H. Wexner, John W Zeiger, Netflix, Inc., RadicalMedia LLC, Leroy & Morton Productions LLC, Lisa Bryant, Joseph Berlinger and President and Fellows of Harvard College |
| Sharon Churcher |
| Miami Herald Media Company and Julie Brown |
| 1:2019cv03377 |
| April 16, 2019 |
| US District Court for the Southern District of New York |
| Loretta A Preska |
| Assault Libel & Slander |
| 28 U.S.C. § 1332 Diversity Action |
| Both |
Docket Report
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This docket was last retrieved on November 9, 2022. A more recent docket listing may be available from PACER.
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Filing 506
STIPULATION OF VOLUNTARY DISMISSAL It is hereby stipulated and agreed by and between the parties and/or their respective counsel(s) that the above-captioned action is voluntarily dismissed, with prejudice against the defendant(s) Virginia L. Giuffre, Alan Dershowitz and without costs pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Document filed by Virginia L. Giuffre. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Moss, Nicole)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT VOLUNTARY DISMISSAL. Notice to Attorney Charles Cooper. RE-FILE Document No. #505 Stipulation of Voluntary Dismissal. The filing is deficient for the following reason(s): the stipulation of voluntary dismissal was not physically signed by all parties who have appeared. Re-file the document using the event type Stipulation of Voluntary Dismissal found under the event list Other Documents - select the correct filer/filers - select the correct party/parties the voluntary dismissal is against - and attach the correct signed (scanned ink signature image) PDF. (tp)
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Filing 505
FILING ERROR - DEFICIENT DOCKET ENTRY - SIGNATURE ERROR - STIPULATION OF VOLUNTARY DISMISSAL It is hereby stipulated and agreed by and between the parties and/or their respective counsel(s) that the above-captioned action is voluntarily dismissed, with prejudice against the defendant(s) Virginia L. Giuffre, Alan Dershowitz and without costs pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure. Document filed by Virginia L. Giuffre. Proposed document to be reviewed and processed by Clerk's Office staff (No action required by chambers)...(Cooper, Charles) Modified on 11/9/2022 (tp).
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Filing 504
ORDER granting #501 Letter Motion for Leave to File Document. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/1/2022) (rro)
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Filing 503
ORDER: Before the Court is Ms. Giuffre's request that the Court permit her counsel to seek an emergency teleconference during next week's deposition of Mr. Dershowitz, should one become necessary. (Dkt. no. 502.) The Court has full confidence that experienced counsel will conduct themselves with professionalism and that Mr. Dershowitz will similarly conduct himself with propriety during the deposition. If warranted, however, the parties may attempt to seek relief from the Court, including, if appropriate, relief under F.R.C.P. 37(a)(3)(B)(i), F.R.C.P. 37(a)(4), and/or F.R.C.P. 30(d)(2). See, e.g., GMAC Bank v. HTFC Corp., 248 F.R.D. 182 (E.D. Pa. 2008). (Signed by Judge Loretta A. Preska on 9/1/2022) (rro)
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Filing 502
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 09/01/2022 Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #501 .(Cooper, Charles)
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Filing 501
LETTER MOTION for Leave to File Letter Under Seal addressed to Judge Loretta A. Preska from Nicole J. Moss dated 09/01/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Minute Entry for proceedings held before Judge Loretta A. Preska: Interim Pretrial Conference held on 7/21/2022. (Court Reporter Sadie Herbert) (mph)
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Filing 500
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated July 19, 2022 re: Response to Plaintiff's Request for Pre-Motion Discovery Conference (ECF No. 494). Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 499
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 07/18/2022 re: Proposed Trial Schedule re #481 ORDER and #483 ORDER. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 498
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated July 18, 2022 re: Response to Court's Order (ECF No. 481) Regarding Case Schedule. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 497
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 07/18/2022 re: Proposed Trial Schedule re #481 ORDER and #483 ORDER. Document filed by Virginia L. Giuffre, Alan Dershowitz.Motion or Order to File Under Seal: #496 .(Cooper, Charles)
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Filing 496
LETTER MOTION for Leave to File Letter Under Seal addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/18/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 495
MEMO ENDORSEMENT on re: #494 Letter,, filed by Virginia L. Giuffre. ENDORSEMENT: Defendant shall respond no later than July 19 at 5:00 p.m. The parties shall be prepared to discuss at the July 21 videoconference. (Signed by Judge Loretta A. Preska on 7/15/2022) (ate)
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Filing 494
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/14/2022 re: Request for Pre-Motion Discovery Conference. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Redacted Email from Howard Cooper to Charles Cooper and Michael Kirk (Apr. 22, 2022), #2 Exhibit B - Pl's Fourth Set of Requests for Production of Documents (May 9, 2022), #3 Exhibit C - Pl's Second Set of Interrogatories (May 9, 2022), #4 Exhibit D - Def. Dershowitzs Objections and Resps. To Pl. Giuffres Fourth Set of Requests for Production (June 22, 2022), #5 Exhibit E - Def. Dershowitzs Answers to Pl. Giuffres Second Set of Interrogatories (June 22, 2022)).(Moss, Nicole)
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Filing 493
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated 07/12/2022 re: Response to plaintiffs 7-5-22 letter (corrected filing). Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #492 .(Cooper, Howard)
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Filing 492
ORDER granting #490 Letter Motion to Seal. The request is granted. This motion (dkt. no. 490) shall be marked as closed. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/12/2022) (vfr)
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Filing 491
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated 07/12/2022 re: ECF 485. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A Declaration of R Giuffre)Motion or Order to File Under Seal: #490 .(Cooper, Howard)
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Filing 490
LETTER MOTION to Seal addressed to Judge Loretta A. Preska from Kristine C. Oren dated 07/12/2022. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 489
ORDER granting #488 Letter Motion for Extension of Time to File Response/Reply re #488 LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Loretta A. Preska from Kristine C Oren dated 07/06/2022. SO ORDERED.. (Signed by Judge Loretta A. Preska on 7/6/2022) Responses due by 7/12/2022 (ks)
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Filing 488
LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Loretta A. Preska from Kristine C Oren dated 07/06/2022. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 487
ORDER granting #484 Letter Motion for Leave to File Document. The request is granted. This motion (dkt. no. 484) shall be marked as closed. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/5/2022) (tg)
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Filing 486
ORDER: The Court is in receipt of Plaintiff's letter dated July 5, 2022. (See dkt. no. 485.) Defendant shall respond by letter no later than Friday July 8, 2022. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/5/2022) (vfr)
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Filing 485
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 07/05/2022 re: Defendant's Violation of the Protective Order. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3)Motion or Order to File Under Seal: #484 .(Cooper, Charles)
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Filing 484
LETTER MOTION for Leave to File Letter Under Seal addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/05/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 483
ORDER granting #482 Letter Motion to Adjourn Conference. The videoconference is adjourned to Thursday July 21 at 11 a.m. Letters shall be filed no later than Monday July 18 at 5 p.m. SO ORDERED. Status Conference set for 7/21/2022 at 11:00 AM before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 6/30/2022) (va)
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Filing 482
LETTER MOTION to Adjourn Conference Currently Scheduled for July 8, 2022 addressed to Judge Loretta A. Preska from Christian G. Kiely dated June 30, 2022. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 481
ORDER: The parties shall appear for a videoconference on Friday July 8, 2022, at 11 a.m. Counsel shall submit letters to the Court containing proposed dates to conclude fact and expert discovery and a list of currently anticipated fact and expert witnesses no later than Wednesday July 6, 2022, at 5:00 p.m. At the same time, counsel shall inform the Court of dates when they are unavailable for trial. Chambers will circulate videoconference information to counsel. Public access is available using the following information: Dial in (877) 402-9753; Access code 6545179. SO ORDERED. (Signed by Judge Loretta A. Preska on 6/29/2022) ( Status Conference set for 7/8/2022 at 11:00 AM before Judge Loretta A. Preska.) (ks)
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Filing 480
ORDER: The Court is in receipt of the parties' letters concerning Ms. Giuffre's deposition. See dkt. nos. 474, 478, 479.) The parties shall appear for a telephonic conference on Defendant's motions on Monday June 6, 2022, at 10 a.m. Given the sensitive nature of the issues raised, the conference will be closed to the public. The parties shall confer and circulate by email (PreskaNYSDChambers@nysd.uscourts.gov) the dial-in information. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/26/2022) (ks)
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Set/Reset Hearings: Telephone Conference set for 6/6/2022 at 10:00 AM before Judge Loretta A. Preska. (ks)
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Filing 479
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated May 25, 2022 re: Reply to Response to Letter Raising Issues Arising from Plaintiff's Deposition. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit B)Motion or Order to File Under Seal: #473 .(Kiely, Christian)
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Filing 478
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/20/2022 re: Response to #474 LETTER re: Issues Arising from Plaintiff's Deposition. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 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 or Order to File Under Seal: #476 .(Cooper, Charles)
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Filing 477
ORDER re: #458 Letter, filed by Alan Dershowitz, Virginia L. Giuffre, #469 Letter filed by Alan Dershowitz. As to Documents 11 and 12, the Court finds that Dershowitz has met his burden of establishing that these communications are protected by the work product privilege and that the privilege was not waived. As to Document 13, the Court finds that any privilege that may have existed has been waived as the stated purpose of the meeting memorandum was to provide information to a reporter from the New York Times. As to Document 14, the Court finds that Dershowitz has failed to meet his burden of establishing that the communication was prepared in anticipation of litigation. By its terms, the communication was prepared for the purpose of revealing certain information to the U.S. Attorney's Office. As to Document 15, the Court finds that Dershowitz has failed to meet his burden of establishing that the communication falls within the protections of the work product privilege. Simply put, this communication is not attorney work product. The unprivileged documents shall be produced forthwith. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/10/2022) (kv)
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Filing 476
ORDER granting #475 Letter Motion for Extension of Time to File Response/Reply re #475 CONSENT LETTER MOTION for Extension of Time to File Response/Reply as to #474 Letter, addressed to Judge Loretta A. Preska from Nicole J. Moss dated 05/10/2022. LETTER MOTION to Seal Response to Defendant's #474 LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 05/10/2022. ( Responses due by 5/20/2022, Replies due by 5/25/2022.); granting #475 Letter Motion to Seal. SO ORDERED.. (Signed by Judge Loretta A. Preska on 5/10/2022) (kv)
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Filing 475
CONSENT LETTER MOTION for Extension of Time to File Response/Reply as to #474 Letter, addressed to Judge Loretta A. Preska from Nicole J. Moss dated 05/10/2022., LETTER MOTION to Seal Response to Defendant's #474 LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 05/10/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 474
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated May 9, 2022 re: Issues Arising from Plaintiff's Deposition. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #473 .(Kiely, Christian)
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Filing 473
ORDER granting #472 Letter Motion to Seal. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/9/2022) (va)
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Filing 472
LETTER MOTION to Seal Letter from Defendant re: Issues Arising from Plaintiff's Deposition addressed to Judge Loretta A. Preska from Christian G. Kiely dated May 6, 2022. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 471
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/19/2022 re: Unsealing Pursuant to #355 ORDER. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit Doc. 204, #2 Exhibit Doc. 205, #3 Exhibit Doc. 205-1, #4 Exhibit Doc. 205-2, #5 Exhibit Doc. 205-3, #6 Exhibit Doc. 205-4, #7 Exhibit Doc. 205-5, #8 Exhibit Doc. 205-6, #9 Exhibit Doc. 205-7, #10 Exhibit Doc. 205-8, #11 Exhibit Doc. 205-9, #12 Exhibit Doc. 217, #13 Exhibit Doc. 218, #14 Exhibit Doc. 218-1, #15 Exhibit Doc. 218-2, #16 Exhibit Doc. 223, #17 Exhibit Doc. 249, #18 Exhibit Doc. 249-1, #19 Exhibit Doc. 250, #20 Exhibit Doc. 250-1, #21 Exhibit Doc. 256, #22 Exhibit Doc. 258, #23 Exhibit Doc. 258-1, #24 Exhibit Doc. 259, #25 Exhibit Doc. 263, #26 Exhibit Doc. 263-1, #27 Exhibit Doc. 263-2, #28 Exhibit Doc. 263-3, #29 Exhibit Doc. 263-4, #30 Exhibit Doc. 263-5, #31 Exhibit Doc. 263-6, #32 Exhibit Doc. 263-7, #33 Exhibit Doc. 265, #34 Exhibit Doc. 285).(Moss, Nicole)
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Filing 470
MEMO ENDORSEMENT on re: #468 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 4/19/2022) (va)
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Filing 469
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated April 18, 2022 re: Response to Plaintiff's Designation of Documents for In Camera Review. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 468
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated April 18, 2022 re: Request to Submit on In Camera, Ex Parte Basis. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 467
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated March 15, 2022 re: Response in Support of Letter Motion re: #465 Letter Motion for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 466
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/09/2022 re: Response in Opposition to #465 LETTER re Letter Motion for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 465
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 9, 2022 re: Letter Motion for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 464
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/18/22 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti)
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Filing 463
TRANSCRIPT of Proceedings re: CONFERENCE held on 3/18/2022 before Judge Loretta A. Preska. Court Reporter/Transcriber: Sharonda Jones, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/28/2022. Redacted Transcript Deadline set for 5/9/2022. Release of Transcript Restriction set for 7/6/2022..(Moya, Goretti)
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Filing 462
ORDER granting #461 Letter Motion for Extension of Time. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/5/2022) (rro)
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Filing 461
LETTER MOTION for Extension of Time to Respond to ECF 458 addressed to Judge Loretta A. Preska from Kristine C. Oren dated 4/05/2022. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 460
ORDER re: #459 Letter, filed by Virginia L. Giuffre. The Court is in receipt of Plaintiff's designation, pursuant to this Court's prior orders, of fifteen communications for in camera review. (See Dkt. no. 459.) Defendant shall produce the following designated communications to the Court no later than Tuesday April 12, 2022: (As further set forth herein.) SO ORDERED. (Signed by Judge Loretta A. Preska on 4/5/2022) (va)
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Filing 459
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/04/2022 re: Plaintiff's Designation of Documents for In Camera Review. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8).(Moss, Nicole)
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Filing 458
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/04/2022 re: Plaintiff's Designation of Documents for In Camera Review. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8)Motion or Order to File Under Seal: #457 .(Moss, Nicole)
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Filing 457
LETTER MOTION to Seal Plaintiff's Designation of Documents for In Camera Review addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/04/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 456
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 2/22/22 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti)
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Filing 455
TRANSCRIPT of Proceedings re: CONFERENCE held on 2/22/2022 before Judge Loretta A. Preska. Court Reporter/Transcriber: Steven Greenblum, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/20/2022. Redacted Transcript Deadline set for 5/2/2022. Release of Transcript Restriction set for 6/28/2022..(Moya, Goretti)
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Filing 454
ADDENDUM TO AGREED PROTECTIVE ORDER: IT IS, THEREFORE, ORDERED with the consent of the parties that an Addendum to the Protective Order be entered for the purposes of assuring the confidentiality of the Neiflix Settlement Agreement, as follows: 1. The Protective Order in this action as entered on December 21, 2020 will govern the production of the Netflix Settlement Agreement. 2. The Netflix Settlement Agreement may be designated "confidential" pursuant to the Protective Order. 3. Pursuant to paragraph 15 of the Protective Order in this action, the signatories to the Netflix Settlement Agreement may petition the Court to restrict the use at trial of the Netflix Settlement Agreement. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/29/2022) (mml)
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Filing 453
PROPOSED ORDER. Document filed by Alan Dershowitz. Related Document Number: #227 ..(Oren, Kristine) Proposed Order to be reviewed by Clerk's Office staff.
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Filing 452
MEMO ENDORSEMENT on re: #449 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 3/28/2022) (jca)
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #453 Proposed Order was reviewed and approved as to form. (km)
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Filing 451
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a TELEPHONE CONFERENCE proceeding held on 3/24/2022 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(yv)
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Filing 450
TRANSCRIPT of Proceedings re: TELEPHONE CONFERENCE held on 3/24/2022 before Judge Loretta A. Preska. Court Reporter/Transcriber: Carole Ludwig, (212) 420-0771. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 4/15/2022. Redacted Transcript Deadline set for 4/25/2022. Release of Transcript Restriction set for 6/23/2022.(yv)
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Filing 449
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 25, 2022 re: Stipulation re: Plaintiffs Proposal Concerning Confidential Netflix Documents (ECF No. 443). Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 448
MEMO ENDORSEMENT on re: #443 Letter, filed by Virginia L. Giuffre. ENDORSEMENT: Upon the consent of the parties, the above is SO ORDERED. (Signed by Judge Loretta A. Preska on 3/24/2022) (va)
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Filing 447
MEMORANDUM OF LAW in Opposition re: #439 MOTION for Protective Order . . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 446
ORDER: The Court is in receipt of the parties' recent lettersregarding the Netflix materials. (Dkt. Nos. 443, 445.) The parties and counsel for Netflix shall appear for a telephonic conference tomorrow March 24, 2022, at 11:00 a.m., using the following information: dial-in (877) 402-9753; access code 6545179. SO ORDERED. ( Telephone Conference set for 3/24/2022 at 11:00 AM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 3/23/2022) (vfr)
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Filing 445
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 22, 2022 re: Response to Plaintiff's Proposal re: Netflix Documents (ECF No. 443). Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 444
MEMO ENDORSEMENT on re: #443 Letter, filed by Virginia L. Giuffre. ENDORSEMENT: Defendant shall respond to Plaintiff's proposal by tomorrow, March 23, 2022, at 3 p.m. The parties shall confer as to whether Plaintiff's deposition may be taken as previously scheduled. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/22/2022) (kv)
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Filing 443
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 03/22/2022 re: #439 MOTION for Protective Order. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Stipulation of Dismissal in Netflix Action).(Cooper, Charles)
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Minute Entry for proceedings held before Judge Loretta A. Preska: Telephone Conference held on 3/18/2022. (Court Reporter Ms. Jones) (mph)
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Filing 442
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/17/2022 re: #437 LETTER MOTION for Extension of Time for Plaintiff's Deposition addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/15/2022. . Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - 02/25/2022 Transcript).(Moss, Nicole)
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Filing 441
LETTER RESPONSE in Opposition to Motion addressed to Judge Loretta A. Preska from Arthur L. Aidala and Howard M. Cooper dated March 17, 2022 re: #437 LETTER MOTION for Extension of Time for Plaintiff's Deposition addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/15/2022. . Document filed by Alan Dershowitz. (Attachments: #1 Exhibit Exhibit A- Transcript of February 22, 2022 status conference).(Aidala, Arthur)
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Filing 440
MEMORANDUM OF LAW in Support re: #439 MOTION for Protective Order . . Document filed by Joseph Berlinger, Lisa Bryant, Leroy & Morton Productions LLC, Netflix, Inc., RadicalMedia LLC..(Strom, Rachel)
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Filing 439
MOTION for Protective Order . Document filed by Joseph Berlinger, Lisa Bryant, Leroy & Morton Productions LLC, Netflix, Inc., RadicalMedia LLC..(Strom, Rachel)
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Filing 438
LETTER RESPONSE in Support of Motion addressed to Judge Loretta A. Preska from Howard M. Cooper dated 03-15-2022 re: #434 LETTER MOTION for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 9, 2022. . Document filed by Alan Dershowitz..(Cooper, Howard)
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Filing 437
LETTER MOTION for Extension of Time for Plaintiff's Deposition addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/15/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 436
LETTER RESPONSE to Motion addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/14/2022 re: #434 LETTER MOTION for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 9, 2022. . Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 435
ORDER: On March 7, 2022, the Court scheduled a teleconference regarding the Harvard issue for March 16 at 1:30 p.m. (Dkt. No. 428.) The conference is adjourned to Friday March 18 at 2:00 p.m. using the same dial-in information. SO ORDERED. ( Telephone Conference set for 3/18/2022 at 02:00 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 3/11/2022) (va)
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Filing 434
LETTER MOTION for Local Rule 37.2 Conference re Request for Relief from Order re: Production of Tax Returns addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 9, 2022. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 433
ORDER: Accordingly, Netflix may move for reconsideration of the Court's order granting Giuffre's motion to compel Dershowitz to produce the documents in the Netflix action. In doing so, the parties shall proceed under the Court's Individual Rule 2.C governing memoranda of law. The briefing schedule shall be as follows: Netflix Opening Brief March 16, 2022. Giuffre Response March 23, 2022. Dershowitz Response March 30, 2022. Netflix Reply April 4, 2022. Should Netflix wish to move for a different form of relief (i.e., a form of relief other than a motion for reconsideration), it may do so on the schedule provided for above. Assuming such a motion is filed, the parties and counsel for Netflix shall appear on April 6, 2022, at 1:00 p.m. for telephonic oral argument on Netflix's motion using the following information: Dial-in: (877) 402-9753; Access code: 6545179. Counsel of record for Netflix will receive notice of this order by ECF. ( Motions due by 3/16/2022., Responses due by 3/30/2022, Replies due by 4/4/2022.), ( Telephone Conference set for 4/6/2022 at 01:00 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 3/9/2022) (ate)
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Filing 432
ADDENDUM TO AGREED PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material...SO ORDERED. (Signed by Judge Loretta A. Preska on 3/8/2022) (kv)
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Filing 431
PROPOSED PROTECTIVE ORDER. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 430
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated 03/08/2022 re: Stipulation from Maxwell Settlement Agreement. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 429
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 7, 2022 re: Reply re: S.D. Fla. Order. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 428
ORDER with respect to #407 Motion to Intervene. The Court is in receipt of the parties', Netflix's, and Harvard's filings relating to the outstanding Netflix and Harvard discovery issues. (See dkt. nos. 407, 408, 410, 414, 415, 420, 421, 422, 423, 424.) Regarding the Netflix issue, the parties shall submit to the Court the transcript of the March 3, 2022 proceedings in the Southern District of Florida action promptly upon receipt. Regarding the Harvard issue, the parties and counsel for Harvard shall appear for a teleconference on Wednesday March 16, 2022 at 1:30 p.m. using the following information: Dial in: (877) 402-9753; Access code 6545179. SO ORDERED.. (Signed by Judge Loretta A. Preska on 3/7/2022) (kv)
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Filing 427
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/07/2022 re: Response to #421 LETTER re S.D. Fla. Order Prohibiting Production of Netflix Documents and #423 LETTER re Response to 03/04/2022 Letter. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Excerpts of Tr. of Discovery Hearing, Dershowitz v. Netflix, No. 21-cv-21961 (S.D. Fla. Mar. 3, 2022), #2 Exhibit B - Tr. of Hearing (Feb. 22, 2022)).(Moss, Nicole)
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Filing 426
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 2/25/22 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti)
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Filing 425
TRANSCRIPT of Proceedings re: CONFERENCE held on 2/25/2022 before Judge Loretta A. Preska. Court Reporter/Transcriber: Alena Lynch, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/28/2022. Redacted Transcript Deadline set for 4/7/2022. Release of Transcript Restriction set for 6/6/2022..(Moya, Goretti)
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Set/Reset Hearings: Telephone Conference set for 3/16/2022 at 01:30 PM before Judge Loretta A. Preska. (kv)
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Filing 424
SECOND LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari dated March 4, 2022 re: Supplemental letter re Clarification on Harvard Reimbursement Order. Document filed by Alan Dershowitz..(Ansari, Imran)
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Filing 423
LETTER addressed to Judge Loretta A. Preska from Rachel F. Strom dated March 4, 2022 re: Response to 03/04/2022 #421 LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 4, 2022. Document filed by Joseph Berlinger, Lisa Bryant, Leroy & Morton Productions LLC, Netflix, Inc., RadicalMedia LLC..(Strom, Rachel)
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Filing 422
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/04/2022 re: Response to #408 LETTER re Clarification on Harvard Reimbursement Order and #420 LETTER re: Rule 45 subpoena to Harvard. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1 - Email from M. McDonnell RE Giuffre v. Dershowitz Terms to exclude from Harvard email searches (Apr. 16, 2021) (excerpt)).(Moss, Nicole)
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Filing 421
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 4, 2022 re: S.D. Fla. Order Prohibiting Production of Netflix Documents. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 420
LETTER addressed to Judge Loretta A. Preska from Andrew W. Schilling dated 03/02/22 re: Rule 45 subpoena to Harvard. Document filed by President and Fellows of Harvard College. (Attachments: #1 Exhibit A - February 18, 2021 Letter).(Schilling, Andrew)
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Filing 419
ORDER re: #416 Proposed Order filed by Alan Dershowitz, #401 Order on Motion for Local Rule 37.2 Conference. Further to the Courts Order dated February 14, 2022 regarding the relevance and discoverability of certain settlements entered into by the parties (Dkt. No. 401), this Court hereby ORDERS (i) that notice of this Order shall be promptly provided to the parties (apart from Plaintiff Virginia Giuffre) as identified in the Settlement Agreement reached in the matter of Giuffre v. Maxwell, Civil Action No. 15-07433; (ii) that such notice shall inform the Maxwell parties that they have one week to file objections, if any, to the disclosure of the Settlement Agreement to the Defendant in this action; and (iii) that if no objections are filed by any party that Plaintiff shall promptly produce a copy of the Settlement Agreement including documents sufficient to show the amount of such settlement. Any such documents shall be produced in their unredacted form and shall be produced confidentially pursuant to the Protective Order entered into by the parties in this case on December 21, 2020 (Dkt. No. 227). SO ORDERED. (Signed by Judge Loretta A. Preska on 2/28/2022) (kv)
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Filing 418
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 2/24/22 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti)
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Filing 417
TRANSCRIPT of Proceedings re: CONFERENCE held on 2/24/2022 before Judge Loretta A. Preska. Court Reporter/Transcriber: Steven Greenblum, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 3/21/2022. Redacted Transcript Deadline set for 3/31/2022. Release of Transcript Restriction set for 5/31/2022..(Moya, Goretti)
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Filing 416
PROPOSED ORDER. Document filed by Alan Dershowitz. Related Document Number: #401 ..(Oren, Kristine) Proposed Order to be reviewed by Clerk's Office staff.
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #416 Proposed Order was reviewed and approved as to form. (km)
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Filing 415
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated February 24, 2022 re: Defendants Position Regarding Production of Confidential Netflix Documents. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 414
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 02/23/2022 re: Response to #410 LETTER re: Response to Letter from Rachel Strom. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Stipulated Protective Order in Netflix Action).(Moss, Nicole)
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Filing 413
ORDER re: #412 Letter filed by President and Fellows of Harvard College. The Court is in receipt of Harvards letter dated February 23, 2022, relating to the parties' disagreement over payment of costs associated with the production of emails from Mr. Dershowitz's Harvard email account. (Dkt. no. 412.) Harvard requests adjournment of the February 24 conference to permit it to respond to Mr. Dershowitz's letter (see dkt. no. 408) and to allow Harvard and the parties to attempt to resolve the issue without Court involvement. The request to adjourn is granted, with the caveat that whatever arrangements are made, the production shall be made promptly. Harvard may respond to Mr. Dershowitz's letter no later than Wednesday March 2, 2022. The parties shall inform the Court by letter no later than Friday March 4, 2022, of the status of the matter. SO ORDERED. (Signed by Judge Loretta A. Preska on 2/23/2022) (kv)
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Filing 412
LETTER addressed to Judge Loretta A. Preska from Andrew Schilling dated 02/23/22 re: Order 409 and adjournment of telephonic hearing.. Document filed by President and Fellows of Harvard College..(Schilling, Andrew)
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Filing 411
NOTICE OF APPEARANCE by Taylor Friedman on behalf of Alan Dershowitz..(Friedman, Taylor)
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Filing 410
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated February 23, 2022 re: Response to Letter from Rachel Strom. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 409
ORDER: Further to the conference held this afternoon, the Court will hear from the parties and from Netflix, which seeks to intervene in this case (see dkt. no. 407), on Thursday February 24 at 10:00 a.m. The Court will hear from the parties and from Harvard regarding the order compelling Mr. Dershowitz to produce additional emails from his Harvard email account (see dkt. no. 401 at 7; dkt. no. 408) on Thursday February 24 at 11:00 a.m. Both hearings will take place by telephone using the following information: Dial in (877) 402-9753; Access Code 6545179. SO ORDERED. Telephone Conference set for 2/24/2022 at 10:00 AM before Judge Loretta A. Preska. Telephone Conference set for 2/24/2022 at 11:00 AM before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 2/22/2022) (kv)
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Filing 408
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated February 22, 2022 re: Clarification on Harvard Reimbursement Order. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Ansari, Imran)
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Filing 407
MOTION to Intervene Letter. Document filed by Netflix, Inc., RadicalMedia LLC, Leroy & Morton Productions LLC, Lisa Bryant, Joseph Berlinger..(Strom, Rachel)
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Filing 406
MEMO ENDORSEMENT on re: #405 Letter, filed by Alan Dershowitz. ENDORSEMENT: The parties shall be prepared to discuss this issue at conference on Tuesday. SO ORDERED. (Signed by Judge Loretta A. Preska on 2/18/2022) (kv)
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Filing 405
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated February 18, 2022 re: Request for Pre-Motion Conference re: Motion to Compel Production of Documents Relating to Lie Detector Examination. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E).(Kiely, Christian)
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Filing 404
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated February 16, 2022 re: Response to Plaintiff's Supplemental Filing re: Discovery Disputes. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 403
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 02/15/2022 re: Supplemental Filing re Docs. 297, 309, 352, 359. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 402
ORDER re: #401 Order on Motion for Local Rule 37.2 Conference. Further to the Court's February 14, 2022 order (dkt. no. 401), the February 22, 2022 discovery conference will begin at 12 p.m. (rather than 11 a.m.) and will take place remotely by video (rather than by telephone). Chambers will separately transmit the video conferencing information to counsel. A listen-only public line will be available using the following information: Dial-in: (877) 402-9753; Access code: 6545179. SO ORDERED. (Discovery Hearing set for 2/22/2022 at 12:00 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 2/15/2022) (kv)
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Filing 401
ORDER granting in part and denying in part #373 Letter Motion for Local Rule 37.2 Conference; granting in part and denying in part #374 Letter Motion for Local Rule 37.2 Conference. For the reasons stated herein, Giuffre's motion to compel (dkt. nos. 373-374) is granted in part, denied in part and reserved in part; and Dershowitz's motion to deem as admitted certain requests for admission (dkt. no. 397) is granted in part. Decision on Dershowitz's motion to compel the production of attorney-client communications (dkt. no. 297) and his motion to exceed ten depositions (dkt. no. 391) is reserved pending the February 22 conference. The parties shall appear for a telephonic conference on Tuesday February 22, 2022 at 11:00 a.m., to discuss the disputes that remain, namely: Dershowitz's motion to compel the production of attorney-client privileged communications due to a purported "at issue" waiver of privilege. (See supra Part I.) Giuffre's motion to compel the production of documents subject to Dershowitz's assertion of the common interest doctrine. (See supra Part II.1.a.) If necessary, the logistics of selection and production of documents for in camera review (See supra Parts II.1.c and II.1.e.) Whether disputes remain over Dershowitz's assertion of the mediation privilege. (See supra Part II.1.d.) Timing of depositions. (See supra Part II.4.) Dershowitz's motion to exceed ten depositions. (See supra Part III.) The information to access the teleconference is as follows: Dial-in: (877) 402-9753; Access code: 6545179. The Court is in receipt of Giuffre's letter dated February 10, 2022 seeking to compel the production of "document productions in Dershowitz v. CNN that contain Documents that [Dershowitz] intends[s] to use to support [his] allegations of injury in that action, irrespective of whether [he has] produced the Documents in this Action." (See Dkt. No. 400 at 1.) Defendant shall respond no later than Wednesday February 16, 2022 at 5:00 p.m., and Plaintiff shall reply no later than Friday February 18, 2022 at 5:00 p.m. If necessary, the parties shall be prepared to discuss this motion at the February 22 conference. SO ORDERED. Telephone Conference set for 2/22/2022 at 11:00 AM before Judge Loretta A. Preska.. (Signed by Judge Loretta A. Preska on 2/14/2022) (kv)
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Filing 400
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 02/10/2022 re: Supplemental Filing re #373 LETTER MOTION for Local Rule 37.2 Conference. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Defendant's Responses to Fifth Set of Requests for Production, #2 Exhibit B - Complaint in Dershowitz v. CNN).(Moss, Nicole)
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Filing 399
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated January 21, 2022 re: Reply to Response to Request for Pre-Motion Conference Re: Motion to Deem as Admitted Unanswered Requests for Admission. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 398
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/20/2022 re: Response in Opposition to #397 LETTER re: Request for Pre-Motion Conference Re: Motion to Deem as Admitted Unanswered Requests for Admission. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 397
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated January 14, 2022 re: Request for Pre-Motion Conference Re: Motion to Deem as Admitted Unanswered Requests for Admission. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D).(Kiely, Christian)
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Filing 396
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/13/2022 re: Giuffre v. Dershowitz, Case No.: 19-cv-03377-LAP Timeliness of Doc. 393. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A).(Moss, Nicole)
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Filing 395
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated January 12, 2022 re: Reply to Response to Request for Pre-Motion Conference Re: Defendant's Motion to Exceed Ten Deposition Limit. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B).(Kiely, Christian)
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Filing 394
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/11/2022 re: Response in Opposition to #391 LETTER re: Request for Pre-Motion Conference Re: Defendant's Motion to Exceed Ten Deposition Limit. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5).(Moss, Nicole)
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Filing 393
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/11/2022 re: Response in Opposition to #391 LETTER re: Request for Pre-Motion Conference Re: Defendant's Motion to Exceed Ten Deposition Limit. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)Motion or Order to File Under Seal: #392 .(Moss, Nicole)
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Filing 392
LETTER MOTION to Seal Response in Opposition to Defendant's Letter Requesting Leave to Exceed Ten Depositions addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/11/2022. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 391
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated January 4, 2022 re: Request for Pre-Motion Conference Re: Defendant's Motion to Exceed Ten Deposition Limit. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 390
ORDER. The Clerk, on or about January 3, 2022, shall unseal the Document. Specifically, the Court shall unseal and place on the public record Dkt. 334-1 in No. 19-cv-3377 and Dkt. 32-1 in No. 21-6702. SO ORDERED. (Signed by Judge Loretta A. Preska and Judge Lewis A. Kaplan on 12/29/21) (yv) Transmission to Sealed Records Clerk for processing.
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Filing 389
ORDER: Accordingly, Mr. Dershowitz's requests to clarify the Protective Order and to strike certain allegations from the complaint (dkt. no. 367) are DENIED. For the reasons stated herein, Mr. Dershowitz's requests to certify an interlocutory appeal of the Protective Order (dkt. no. 366), to clarify the scope of the Protective Order, and to strike certain allegations from the complaint (dkt. no. 367) are DENIED. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/21/2021) (va)
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Filing 388
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 12/15/2021 re: #366 LETTER Request for Certification of Interlocutory Appeal. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Cooper, Charles)
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Filing 387
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 12/15/2021 re: #366 LETTER Request for Certification of Interlocutory Appeal. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)Motion or Order to File Under Seal: #383 .(Cooper, Charles)
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Filing 386
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 12/15/2021 re: #367 LETTER Request for Leave to File Motion to Strike and for Clarification. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 385
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/15/2021 re: #374 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. . Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit S, #2 Exhibit T, #3 Exhibit U).(Moss, Nicole)
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Filing 384
***SELECTED PARTIES***LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/15/2021 re: #373 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. . Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit S, #2 Exhibit T, #3 Exhibit U)Motion or Order to File Under Seal: #383 .(Moss, Nicole)
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Filing 383
LETTER MOTION to Seal Reply in Support of LR 37.2 Letter and Response to Request for Certification of Interlocutory Appeal addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/15/2021. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 382
ORDER. In the absence of a showing, on or before December 22, 2021, of good cause by a party to either of these actions or by a duly authorized executor, administrator, or other representative of the Estate Mr. Epstein, the Court will file the entire Document on the public record on or about January 3, 2022. SO ORDERED. (Signed by Judge Lewis A. Kaplan on 12/14/21) (yv)
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Filing 381
LETTER RESPONSE in Opposition to Motion addressed to Judge Loretta A. Preska from Christian G. Kiely dated December 13, 2021 re: #374 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. REDACTED VERSION. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Kiely, Christian)
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Filing 380
***SELECTED PARTIES***LETTER RESPONSE in Opposition to Motion addressed to Judge Loretta A. Preska from Christian G. Kiely dated December 13, 2021 re: #373 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. . Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C)Motion or Order to File Under Seal: #379 .(Kiely, Christian)
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Filing 379
LETTER MOTION to Seal Defendant's Response to Plaintiff's Request for Pre-Motion Discovery Conference addressed to Judge Loretta A. Preska from Christian G. Kiely dated December 13, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 378
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a conference proceeding held on 11/16/2021 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(Moya, Goretti)
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Filing 377
TRANSCRIPT of Proceedings re: conference held on 11/16/2021 before Judge Loretta A. Preska. Court Reporter/Transcriber: Rose Prater, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/30/2021. Redacted Transcript Deadline set for 1/10/2022. Release of Transcript Restriction set for 3/9/2022..(Moya, Goretti)
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Filing 376
ANSWER to #362 Amended Complaint, with JURY DEMAND. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 375
ORDER granting #371 Letter Motion to Seal; with respect to #374 Letter Motion for Local Rule 37.2 Conference. Defendant shall file a response, if any, no later than Monday December 13, 2021. Plaintiff shall file a reply, if any, by Wednesday December 15, 2021. Plaintiff's motion to seal (dkt. nos. 371, 372) is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/6/2021) (va)
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Set/Reset Deadlines: Responses due by 12/13/2021. Replies due by 12/15/2021. (va)
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Filing 374
LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. Document filed by Virginia L. Giuffre. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R).(Moss, Nicole)
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Filing 373
***SELECTED PARTIES*** LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P, #17 Exhibit Q, #18 Exhibit R)Motion or Order to File Under Seal: #371 .(Moss, Nicole)
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Filing 372
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021 re: Supplemental Submission re #371 LETTER MOTION to Seal Local Rule 37.2 Letter. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 371
LETTER MOTION to Seal Local Rule 37.2 Letter addressed to Judge Loretta A. Preska from Nicole J. Moss dated 12/03/2021. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 370
ORDER granting #369 Letter Motion for Extension of Time. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/2/2021) (va)
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Filing 369
CONSENT LETTER MOTION for Extension of Time to Respond to #366 and #367 addressed to Judge Loretta A. Preska from Charles J. Cooper dated 12/02/2021. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 368
ORDER re: #366 Letter filed by Alan Dershowitz. The Court is in receipt of Defendant's December 1, 2021 letter requesting that the Court certify its November 10, 2021 protective order for interlocutory appeal. Plaintiff shall file any response no later than December 8, 2021. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/1/2021) (va)
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Filing 367
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated December 1, 2021 re: Request for Leave to File Motion to Strike and for Clarification. Document filed by Alan Dershowitz. (Attachments: #1 Appendix A, #2 Appendix B).(Kiely, Christian)
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Filing 366
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated December 1, 2021 re: Request for Certification of Interlocutory Appeal. Document filed by Alan Dershowitz. (Attachments: #1 Appendix A).(Kiely, Christian)
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Filing 365
MEMO ENDORSEMENT on re: #364 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. Alan Dershowitz answer due 12/7/2021. (Signed by Judge Loretta A. Preska on 11/23/2021) (va)
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Filing 364
LETTER addressed to Judge Loretta A. Preska from Kristine C. Oren dated November 22, 2021 re: Request for Extension. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 363
EXHIBIT TO PLEADING re: #362 Amended Complaint,. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Charles J Cooper re: Document No. #362 Amended Complaint. The filing is deficient for the following reason(s): the order granting permission to file the pleading was not attached; Court's leave has not been granted. File the Exhibit to Pleading event found under the event list Other Documents and attach either opposing party's written consent or Court's leave. (vf)
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Filing 362
FILING ERROR - DEFICIENT PLEADING - FRCP RULE 15 NON-COMPLIANCE -SECOND AMENDED COMPLAINT amending #117 Amended Complaint, #1 Complaint,, against Alan Dershowitz with JURY DEMAND.Document filed by Virginia L. Giuffre. Related document: #117 Amended Complaint, #1 Complaint,,..(Cooper, Charles) Modified on 11/17/2021 (vf).
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Filing 361
ORDER granting #358 Letter Motion to Seal. The sealing request is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/15/2021) (va)
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Filing 360
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/12/2021 re: Supplemental Filing in Opposition to #297 Motion to Compel. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Boylan Deposition Excerpts, #2 Exhibit B - Spallholtz Deposition Excerpts, #3 Exhibit C - Redacted Giuffre Deposition Excerpts).(Cooper, Charles)
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Filing 359
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/12/2021 re: Supplemental Filing in Opposition to #297 Motion to Compel. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit A - Boylan Deposition Excerpts, #2 Exhibit B - Spallholtz Deposition Excerpts, #3 Exhibit C - Giuffre Deposition Excerpts)Motion or Order to File Under Seal: #358 .(Cooper, Charles)
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Filing 358
LETTER MOTION to Seal Supplemental Filing addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/12/2021. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 357
NOTICE OF APPEARANCE by Cynthia Gierhart on behalf of Julie Brown, Miami Herald Media Company..(Gierhart, Cynthia)
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Filing 356
NOTICE OF APPEARANCE by Christine Walz on behalf of Julie Brown, Miami Herald Media Company..(Walz, Christine)
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Filing 355
ORDER granting #303 Letter Motion for Local Rule 37.2 Conference. Counsel for the parties shall appear by video for a status conference on November 16, 2021 at 2:00 p.m. The Court will communicate separately to counsel information for joining the conference. Members of the public may observe the conference using the following listen-only conference line: (877) 402-9753 Access code 6545179. The Clerk of Court is directed to close the open motions at dkt. nos. 270, 303, and 304. SO ORDERED. Status Conference set for 11/16/2021 at 02:00 PM before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 11/10/2021) (va)
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Filing 354
ORDER granting #353 Letter Motion for Extension of Time. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/10/2021) (ate)
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Filing 353
LETTER MOTION for Extension of Time /Setting Deadline for Response to #352 LETTER re Supplemental Filing Re: Motion to Compel addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/04/2021. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 352
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated November 2, 2021 re: Supplemental Filing Re: Motion to Compel ECF No. 297. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B).(Kiely, Christian)
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Filing 351
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/01/2021 re: Request for Status Conference. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 350
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated October 27, 2021 re: Request for Status Conference (REDACTED VERSION). Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 349
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated October 27, 2021 re: Request for Status Conference. Document filed by Alan Dershowitz, Virginia L. Giuffre.Motion or Order to File Under Seal: #348 .(Kiely, Christian)
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Filing 348
ORDER granting #347 Letter Motion to Seal. So Ordered. (Signed by Judge Loretta A. Preska on 10/26/2021) (va)
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Filing 347
LETTER MOTION to Seal Letter Requesting a Status Conference addressed to Judge Loretta A. Preska from Kristine C. Oren dated 10/22/2021. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 346
MEMO ENDORSEMENT on re: #345 Letter filed by Virginia L. Giuffre. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 10/6/2021) (va)
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Filing 345
LETTER addressed to Judge Loretta A. Preska from David Boies dated September 30, 2021 re: Request to Provide Document. Document filed by Virginia L. Giuffre..(Boies, David)
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Filing 344
LETTER addressed to Judge Loretta A. Preska from David Boies dated September 23, 2021 re: Request to Provide Document. Document filed by Virginia L. Giuffre..(Boies, David)
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Filing 343
ORDER: Accordingly, for the reasons noted above, Mr. Dershowitz's request to permit disclosure of the settlement agreement (dkt. nos. 334, 335) is denied. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/16/2021) (ks)
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Filing 342
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated September 14, 2021 re: REDACTED Reply to Response to Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit D, #2 Exhibit E, #3 Exhibit F).(Kiely, Christian)
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Filing 341
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated September 14, 2021 re: Reply to Response to Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit D, #2 Exhibit E, #3 Exhibit F)Motion or Order to File Under Seal: #333 .(Kiely, Christian)
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Filing 340
LETTER addressed to Judge Loretta A. Preska from David Boies dated September 13, 2021 re: Response to Pre-Motion Letter re: Motion for Limited Relief from Protective Order (ECF No. 334). Document filed by Virginia L. Giuffre..(Boies, David)
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Filing 339
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 09/13/2021 re: REDACTED Response to #334 Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 338
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 09/13/2021 re: Response to #334 Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Virginia L. Giuffre, Alan Dershowitz.Motion or Order to File Under Seal: #337 .(Cooper, Charles)
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Filing 337
MEMO ENDORSEMENT on re: #336 Letter filed by Virginia L. Giuffre. ENDORSEMENT: The sealing request is granted. Counsel shall file a redacted version of the letter on the public docket. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/13/2021) (va)
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Filing 336
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 09/08/2021 re: Permission to File Under Seal. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 335
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated September 8, 2021 re: REDACTED Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D).(Kiely, Christian)
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Filing 334
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated September 8, 2021 re: Pre-Motion Letter re: Motion for Limited Relief from Protective Order. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D)Motion or Order to File Under Seal: #333 .(Kiely, Christian)
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Filing 333
ORDER granting #332 Letter Motion to Seal. The sealing request is granted. Additionally, Mr. Dershowitz shall file his letter on the public docket. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/8/2021) (tg)
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Filing 332
LETTER MOTION to Seal Pre-Motion Letter Seeking Certain Limited Relief addressed to Judge Loretta A. Preska from Christian G. Kiely dated September 2, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 331
STIPULATION OF PARTIAL DISMISSAL: IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff and Defendant, by and through their undersigned attorneys, as follows: 1. Count II of the Amended Complaint shall be and is hereby voluntarily dismissed, with prejudice, pursuant to Rule 41(a)(1)(A)(ii) of the Federal Rules of Civil Procedure, without costs or fees to either party. (As further set forth herein.) SO ORDERED. (Signed by Judge Loretta A. Preska on 8/16/2021) (va)
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Filing 330
PROPOSED STIPULATION AND ORDER. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 329
ORDER granting #328 Letter Motion to Seal. The sealing request is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 8/6/2021) (va)
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Filing 328
LETTER MOTION to Seal pre-motion conference letter addressed to Judge Loretta A. Preska from Howard M. Cooper dated 08/05/2021. Document filed by Alan Dershowitz. Return Date set for 8/5/2021 at 05:06 PM..(Oren, Kristine)
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Filing 327
ADDENDUM TO AGREED PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... SO ORDERED. (Signed by Judge Loretta A. Preska on 8/2/2021) (va)
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Filing 326
PROPOSED PROTECTIVE ORDER. Document filed by Virginia L. Giuffre..(Proctor, Haley)
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Filing 325
ORDER: granting #322 Letter Motion for Local Rule 37.2 Conference. For the reasons set out above, Plaintiff's motion for leave to serve certain interrogatories on Defendant (dkt. no. 322) is GRANTED. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/28/2021) (ama)
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Filing 324
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/27/2021 re: #322 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/21/2021. . Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit C - DERSH047430).(Moss, Nicole)
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Filing 323
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated July 26, 2021 re: Response to Plaintiff's Letter Motion for Local Rule 37.2 Conference. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B).(Kiely, Christian)
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Filing 322
LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Nicole J. Moss dated 07/21/2021. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Giuffre's First Set of Interrogatories to Dershowitz, #2 Exhibit B - Email re Interrogatories).(Moss, Nicole)
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Filing 321
REPLY AFFIDAVIT of Christian G. Kiely in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 320
REPLY to Response to Motion re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . REDACTED VERSION. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 319
***SELECTED PARTIES***REPLY AFFIDAVIT of Christian G. Kiely in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #296 .(Kiely, Christian)
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Filing 318
***SELECTED PARTIES*** REPLY to Response to Motion re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . . Document filed by Alan Dershowitz, Virginia L. Giuffre. Motion or Order to File Under Seal: #296 .(Kiely, Christian)
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Filing 317
ORDER granting #314 Letter Motion for Leave to File Excess Pages. The requested enlargement of pages is approved. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/26/2021) (va)
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Filing 316
ORDER granting #315 Letter Motion for Leave to File Excess Pages. The requested enlargement of pages is approved. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/26/2021) (va)
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Filing 315
LETTER MOTION for Leave to File Excess Pages addressed to Judge Loretta A. Preska from Christian G. Kiely dated May 25, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 314
LETTER MOTION for Leave to File Excess Pages addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/25/2021. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 313
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/21/2021 re: Combined Reply to Defendant's Response to Plaintiff's Pre-Motion Letter seeking Leave to Amend the Complaint (Doc. No. 304) and Letter Motion for Local Rule 37.2 Conference re Protective Order (Doc. No. 303). Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 312
DECLARATION of Haley N. Proctor in Opposition re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5).(Proctor, Haley)
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Filing 311
RESPONSE in Opposition to Motion re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 310
***SELECTED PARTIES***DECLARATION of Haley N. Proctor in Opposition re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5)Motion or Order to File Under Seal: #305 .(Cooper, Charles)
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Filing 309
***SELECTED PARTIES*** RESPONSE in Opposition to Motion re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . . Document filed by Virginia L. Giuffre, Alan Dershowitz. Motion or Order to File Under Seal: #305 .(Cooper, Charles)
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Filing 308
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated May 14, 2021 re: Response to Plaintiff's Pre-Motion Letters Seeking Leave to Amend (ECF No. 304) and for a Protective Order (ECF No. 303). Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B).(Kiely, Christian)
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Filing 307
ORDER granting #306 Letter Motion for Extension of Time to File Response/Reply as to #304 Letter, #303 LETTER MOTION for Local Rule 37.2 Conference re: Protective Order addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/06/2021. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/7/2021) (va)
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Filing 306
LETTER MOTION for Extension of Time to File Response/Reply as to #304 Letter, #303 LETTER MOTION for Local Rule 37.2 Conference re: Protective Order addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/06/2021. addressed to Judge Loretta A. Preska from Kristine C. Oren dated May 6, 2021. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 305
MEMO ENDORSEMENT on re: #302 Letter filed by Virginia L. Giuffre. ENDORSEMENT: Because the sealed material is subject to the protective order, sealing is appropriate. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/6/2021) (va)
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Filing 304
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/06/2021 re: Request for Permission To File Motion To Amend Complaint. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A - Excerpts from Plaintiff's Objections & Responses to Defendant's First Requests For Production to Giuffre, #2 Exhibit B - Proposed Second Amended Complaint, #3 Exhibit C - Redline of Proposed Second Amended Complaint).(Cooper, Charles)
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Filing 303
LETTER MOTION for Local Rule 37.2 Conference re: Protective Order addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/06/2021. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 302
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 05/05/2021 re: Permission to File Under Seal. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 301
AFFIDAVIT of Christian G. Kiely in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Alan Dershowitz. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M).(Kiely, Christian)
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Filing 300
MEMORANDUM OF LAW in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . REDACTED VERSION. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 299
***SELECTED PARTIES***AFFIDAVIT of Christian G. Kiely in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination .. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M)Motion or Order to File Under Seal: #296 .(Kiely, Christian)
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Filing 298
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re: #297 MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . . Document filed by Alan Dershowitz, Virginia L. Giuffre. Motion or Order to File Under Seal: #296 .(Kiely, Christian)
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Filing 297
MOTION to Compel Plaintiff Virginia Giuffre to Produce Certain Attorney-Client Communications on the Basis of Waiver, Or, In the Alternative, Request for Zolin Examination . Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 296
ORDER granting #295 Letter Motion to Seal. Because the materials to be filed contain material designated confidential pursuant to applicable protective orders, counsel may file the motion under seal with a redacted copy on the public docket. SO ORDERED. (Signed by Judge Loretta A. Preska on 5/4/2021) (va)
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Filing 295
LETTER MOTION to Seal Memorandum in Support of Defendant's Motion to Compel the Production of Certain Attorney-Client Communications on the Basis of Waiver, or, in the Alternative, Request for Zolin Examination addressed to Judge Loretta A. Preska from Christian G. Kiely dated May 3, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 294
REPLY re: #270 Letter to Intervene and Unseal. Document filed by Julie Brown, Miami Herald Media Company..(Walz, Christine)
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Filing 293
NOTICE of Intent to Request Redaction by Charles J Cooper re #284 Transcript,,..(Cooper, Charles)
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Filing 292
MEMO ENDORSEMENT: on re: #291 Letter filed by Alan Dershowitz. ENDORSEMENT: The proposed briefing schedule is approved. SO ORDERED., ( Motions due by 5/4/2021., Responses due by 5/20/2021, Replies due by 5/27/2021.) (Signed by Judge Loretta A. Preska on 4/19/2021) (ama)
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Filing 291
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated April 16, 2021 re: Proposed Briefing Schedule for Defendant's Motion to Compel the Production of Certain Attorney-Client Communications. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 290
LETTER addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated April 15, 2021 re: Response to Miami Herald's Motion to Intervene. Document filed by Leslie H. Wexner, John W Zeiger..(Little, Marion)
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Filing 289
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated April 15, 2021 re: Response to #270 Letter Motion to Intervene and Unseal. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 288
NOTICE of Intent to Request Redactions Via Motion re: #285 Notice of Filing Transcript,,. Document filed by Leslie H. Wexner, John W Zeiger..(Little, Marion)
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Filing 287
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated April 15, 2021 re: Response to Miami Herald Letter Motion to Intervene and Unseal. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 286
ORDER: The Court has reviewed Defendant's letters seeking leave to file a motion to compel production of certain communications between Plaintiff and her counsel on the basis of waiver and, alternatively, seeking the Court's review of certain communications in camera to determine whether the crime-fraud exception applies. Defendant may proceed with the motion. Defendant's opening brief and Plaintiff's opposition brief each shall not exceed 15 pages. Defendant may file a reply brief of no longer than 5 pages. The parties shall confer and propose a briefing schedule. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/14/2021) (va)
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Filing 285
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 3/25/21 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(McGuirk, Kelly)
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Filing 284
TRANSCRIPT of Proceedings re: CONFERENCE held on 3/25/2021 before Judge Loretta A. Preska. Court Reporter/Transcriber: Eve Giniger, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 5/5/2021. Redacted Transcript Deadline set for 5/17/2021. Release of Transcript Restriction set for 7/13/2021..(McGuirk, Kelly)
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Filing 283
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated April 13, 2021 re: Reply re: Motion to Compel Production of Certain Attorney-Client Communications. Document filed by Alan Dershowitz, Virginia L. Giuffre.Motion or Order to File Under Seal: #269 .(Kiely, Christian)
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Filing 282
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 04/12/2021 re: Response to #274 re: Motion to Compel Production of Certain Attorney-Client Communications. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit 1)Motion or Order to File Under Seal: #278 .(Cooper, Charles)
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Filing 281
ORDER re: #275 Letter filed by Alan Dershowitz. Mr. Dershowitz's request to compel Plaintiff to submit to her first day of deposition by video in April or May (dkt. no. 275) is denied without prejudice, subject to reinstatement upon the substantial completion of paper discovery. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/9/2021) (va)
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Filing 280
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated April 8, 2021 re: Reply re: Motion to Compel Plaintiff to Appear for Day 1 of Her Deposition Via Zoom. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 279
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/08/2021 re: Response to #275 LETTER re: Pre-Motion Letter re: Motion to Compel Plaintiff to Appear for Day 1 of Her Deposition Via Zoom. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 278
MEMO ENDORSEMENT on re: #277 Letter filed by Virginia L. Giuffre. ENDORSEMENT: Counsel's requests to file a response under seal and to discuss Defendant's pre-motion letter with Plaintiff's prior counsel are approved. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/7/2021) (va)
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Filing 277
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 04/06/2021 re: Permission to File Under Seal. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 276
ORDER: The Court is in receipt of the April 2, 2021 letters from Defendant seeking to compel Plaintiffs testimony (dkt. no. 275) and the production of certain documents (dkt. no. 274). Plaintiff shall file any responses to these letters no later than April 12, 2021. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/5/2021) (jca)
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Filing 275
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated April 2, 2021 re: Pre-Motion Letter re: Motion to Compel Plaintiff to Appear for Day 1 of Her Deposition Via Zoom. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 274
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated April 2, 2021 re: Pre-Motion Letter re: Motion to Compel Production of Certain Attorney-Client Communications. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F)Motion or Order to File Under Seal: #269 .(Kiely, Christian)
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Filing 273
MEMO ENDORSEMENT on re: #270 Letter filed by Julie Brown, Miami Herald Media Company. ENDORSEMENT: Any party opposing the Miami Herald's motion to intervene and to unseal certain documents shall file opposing papers no later than April 15, 2021. Any reply shall be filed no later than April 22, 2021. SO ORDERED. ( Responses due by 4/15/2021. Replies due by 4/22/2021.) (Signed by Judge Loretta A. Preska on 4/1/2021) (va)
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Filing 272
NOTICE OF APPEARANCE by Barry Kamins on behalf of Alan Dershowitz..(Kamins, Barry)
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Filing 271
NOTICE OF APPEARANCE by John M. Leventhal on behalf of Alan Dershowitz..(Leventhal, John)
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Filing 270
LETTER addressed to Judge Loretta A. Preska from Christine N. Walz dated 3/31/2021 re: request to intervene and unseal documents. Document filed by Julie Brown, Miami Herald Media Company..(Walz, Christine)
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Filing 269
ORDER granting #266 Letter Motion for Leave to File Document. The sealing request is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/26/2021) (va)
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Filing 268
ORDER: The conference scheduled for March 25, 2021 at 1:30 p.m. EST will occur by video. The Court will communicate separately to counsel information for joining the videoconference. Members of the public may access the conference using the following listen-only teleconference line: (877) 226-8216, access code: 3329593. The Court will open the teleconference line to the public after counsel has addressed the sealed motions at dkt. nos. 249 and 250, which contain materials designated confidential under the protective order. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/24/2021) (va)
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Filing 267
ADDENDUM TO AGREED PROTECTIVE ORDER: IT IS, THEREFORE, ORDERED with the consent of the parties that an Addendum to the Protective Order be entered for the purposes of assuring the confidentiality of the protected information which may be disclosed by Mr. Pottinger in response to discovery or a subpoena, in response to orders of the Court, in conjunction with the filing of any motion or response thereto, or otherwise during the hearing of this matter as follows: 1. The Protective Order in this action as entered on December 21, 20201 will govern Mr. Pottinger's production in this matter, and Mr. Pottinger and the parties shall be bound by the Protective Order's provisions with respect to Mr. Pottinger's production. 2. However, as to Mr. Pottinger, Paragraph 2 of the Protective Order shall be modified as follows in bold, as further set forth. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/15/2021) (mml)
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Filing 266
LETTER MOTION for Leave to File Pre-Motion Letter Under Seal addressed to Judge Loretta A. Preska from Howard M. Cooper dated March 16, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 265
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated March 16, 2021 re: Reply re: Defendant's Renewed Request to Compel Deposition of Leslie Wexner. Document filed by Alan Dershowitz, Virginia L. Giuffre, Leslie H. Wexner, John W Zeiger.Motion or Order to File Under Seal: #248 .(Kiely, Christian)
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Filing 264
ORDER granting #262 Letter Motion to Continue. The request for an adjournment is granted. The conference is rescheduled for March 25, 2021 at 1:30 pm. SO ORDERED. Status Conference set for 3/25/2021 at 01:30 PM before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 3/16/2021) (va)
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Filing 263
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 03/10/2021 re: Response to #250 LETTER re: Pre-Motion Conference to Provide Information and Materials to the US Attorney's Office. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G)Motion or Order to File Under Seal: #260 .(Cooper, Charles)
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Filing 262
LETTER MOTION to Continue Status Conference Currently Scheduled for March 18, 2021 addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 15, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 261
ORDER: Counsel for the parties shall appear for a videoconference on March 18, 2021 at 11:00 a.m. to address the issues raised in their pre-motion conference letters (dkt. nos. 242, 249, 250). Counsel for Mr. Wexner also shall appear to address Mr. Dershowitz's renewed motion to compel Mr. Wexner's testimony (dkt. no. 249). The Court will communicate separately to counsel information for joining the videoconference. The Court will docket call-in information for the public before the conference. SO ORDERED. ( Status Conference set for 3/18/2021 at 11:00 AM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 3/15/2021) (va)
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Filing 260
ORDER granting #255 Letter Motion for Leave to File Document. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/12/2021) (va)
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Filing 259
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated March 12, 2021 re: Response to Alan Dershowitz March 4, 2021 Letter. Document filed by Virginia L. Giuffre, Alan Dershowitz, Leslie H. Wexner.Motion or Order to File Under Seal: #248 .(Little, Marion)
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Filing 258
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/12/2021 re: Renewed Request to Compel Deposition of Leslie Wexner. Document filed by Virginia L. Giuffre, Alan Dershowitz, Leslie H. Wexner, John W Zeiger. (Attachments: #1 Exhibit 1)Motion or Order to File Under Seal: #254 .(Moss, Nicole)
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Filing 257
PROPOSED PROTECTIVE ORDER. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 256
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated 03/11/2021 re: Letter in Reply and in Further Support of Alan Dershowitz's Letter Re: Pre-Motion Conference seeking Permission to Provide Information and Materials to the U.S. Attorney's Office. Document filed by Virginia L. Giuffre, Alan Dershowitz.Motion or Order to File Under Seal: #246 .(Ansari, Imran)
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Filing 255
LETTER MOTION for Leave to File Response to Defendant's Pre-Motion Letter Under Seal re: Doc. 245 Letter Motion for Leave to File Pre-Motion Letter Under Seal addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/09/2021. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 254
ORDER granting #251 Letter Motion for Leave to File Document. Counsel's request for an extension of time to March 12, 2021 to file a response letter and the request to file that letter under seal are granted. Defendant shall file any reply no later than March 16, 2021. So Ordered. (Signed by Judge Loretta A. Preska on 3/8/2021) (js)
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Filing 253
ORDER granting #252 Letter Motion for Extension of Time. Counsel's request for an extension of time to March 12, 2021 to file a response letter and the request to file that letter under seal are granted. Defendant shall file any reply no later than March 16, 2021. So Ordered. (Signed by Judge Loretta A. Preska on 3/8/2021) (js)
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Filing 252
LETTER MOTION for Extension of Time addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated March 8, 2021. Document filed by Leslie H. Wexner..(Little, Marion)
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Filing 251
LETTER MOTION for Leave to File Response to Defendant's Pre-Motion Letter Under Seal with Extension of Time to File addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/08/2021. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Set/Reset Deadlines: Responses due by 3/12/2021 Replies due by 3/16/2021. (js)
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Filing 250
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari dated 03/05/2021 re: Pre-Motion Conference to Provide Information and Materials to the US Attorney's Office. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit Letter to Strauss)Motion or Order to File Under Seal: #246 .(Ansari, Imran)
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Filing 249
***SELECTED PARTIES*** LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated March 4, 2021 re: Renewed Request to Compel Deposition of Leslie Wexner. Document filed by Alan Dershowitz, Virginia L. Giuffre, Leslie H. Wexner. (Attachments: #1 Exhibit A)Motion or Order to File Under Seal: #248 .(Kiely, Christian)
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Filing 248
ORDER granting #243 Letter Motion for Leave to File Document. The request for leave to file a letter under seal is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/4/2021) (va)
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Filing 247
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 03/04/2021 re: Reply Letter: Motion to Compel. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 246
ORDER granting #245 Letter Motion for Leave to File Document. The request for leave to file a pre-motion conference letter under seal is granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 3/4/2021) (va) Modified on 3/4/2021 (va).
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Filing 245
LETTER MOTION for Leave to File Pre-Motion Letter Under Seal addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated March 3, 2021. Document filed by Alan Dershowitz..(Ansari, Imran)
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Filing 244
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated March 3, 2021 re: Response to Pre-Motion Letter. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E).(Kiely, Christian)
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Filing 243
LETTER MOTION for Leave to File Pre-Motion Letter Under Seal addressed to Judge Loretta A. Preska from Howard M. Cooper dated March 3, 2021. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 242
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 02/26/2021 re: Pre-Motion Letter: Motion To Compel. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 241
FILING ERROR - DEFICIENT DOCKET ENTRY (SEE DOCUMENT #242) - LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 02/26/2021 re: Pre-Motion Letter: Motion To Compel. Document filed by Virginia L. Giuffre..(Moss, Nicole) Modified on 3/1/2021 (ldi).
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Filing 240
OPINION & ORDER re: #203 MOTION to Disqualify Counsel, filed by Alan Dershowitz. For the reasons described above, Defendant's motion to disqualify the law firm of Cooper & Kirk (dkt. no. 203) is denied. The Clerk of the Court shall close the open motion. SO ORDERED. (Signed by Judge Loretta A. Preska on 1/28/2021) (va)
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Filing 239
MEMO ENDORSEMENT on re: #238 Reply to Response to Motion, filed by Sharon Churcher. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 1/22/2021) (va)
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Filing 238
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Laura R. Handman dated January 21, 2021 re: #199 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. . Document filed by Sharon Churcher..(Handman, Laura)
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Filing 237
JOINT LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss, Howard M. Cooper, & Arthur L. Aidala dated 01/20/2021 re: Request for clarification of #233 ORDER. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 236
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/15/21 re: Joint Status Report re Party Depositions. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 235
MEMO ENDORSEMENT on re: #234 Reply to Response to Motion, filed by Sharon Churcher. ENDORSEMENT: Ms. Churcher's request for a pre-motion conference will be held in abeyance through January 21, 2021. SO ORDERED. (Signed by Judge Loretta A. Preska on 1/8/2021) (va)
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Filing 234
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Laura R. Handman dated 1/7/2021 re: #199 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. Requesting Court to hold request for pre-motion conference in abeyance until January 21, 2021. Document filed by Sharon Churcher..(Handman, Laura)
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Filing 233
ORDER: The Court does not read the protective order, as presently entered, to give the parties unrestricted authority to disclose publicly the confidential materials from Maxwell--not least of all because the parties only may agree to downgrade confidentiality designations for materials that the "designating party has subsequently produced in this action," i.e., only materials that Ms. Giuffre alone designated as confidential in Maxwell. To avoid any doubt, however, the parties shall append to the end of the definition of "Confidential Information" in the protective order the underlined language at the end of the following excerpt, which makes clear that the parties cannot agree to unseal the identities of non-party Does where that information is still sealed in Maxwell: (As further set forth herein this Order.) The parties shall file a revised protective order with this language appended to the definition of "Confidential Information." SO ORDERED. (Signed by Judge Loretta A. Preska on 1/6/2021) (va)
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Filing 232
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated January 5, 2021 re: Protective Order. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 231
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 01/05/2021 re: Protective Order. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 230
ORDER granting #229 Letter Motion for Extension of Time to File Response/Reply. Professor Dershowitz and Ms. Giuffre may respond no later than January 5, 2021. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/24/2020) (mml)
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Filing 229
LETTER MOTION for Extension of Time to File Response/Reply addressed to Judge Loretta A. Preska from Kristine C. Oren dated 12/23/2020. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 228
JOINT LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper, Howard M. Cooper, and Arthur L. Aidala dated 12/22/2020 re: Discovery Status. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 227
AGREED PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... SO ORDERED AND SIGNED this 21 day of December, 2020. (Signed by Judge Loretta A. Preska on 12/21/2020) (va)
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Filing 226
PROPOSED PROTECTIVE ORDER. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 225
REPLY MEMORANDUM OF LAW in Support re: #203 MOTION to Disqualify Counsel . REDACTED VERSION. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 224
DECLARATION of Christian G. Kiely in Support re: #203 MOTION to Disqualify Counsel .. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Kiely, Christian)
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Filing 223
***SELECTED PARTIES*** REPLY MEMORANDUM OF LAW in Support re: #203 MOTION to Disqualify Counsel . . Document filed by Alan Dershowitz, Virginia L. Giuffre. Motion or Order to File Under Seal: #200 .(Kiely, Christian)
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Filing 222
ORDER holding in abeyance #199 Letter Motion for Local Rule 37.2 Conference. The request for a pre-motion conference (dkt. no. 199) will be held in abeyance through January 7, 2020. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/9/2020) (va)
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Filing 221
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Laura R. Handman dated December 8, 2020 re: #199 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. . Document filed by Sharon Churcher..(Handman, Laura)
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Filing 220
DECLARATION of Nicole J. Moss in Opposition re: #203 MOTION to Disqualify Counsel .. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A, #2 Exhibit B).(Moss, Nicole)
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Filing 219
RESPONSE in Opposition to Motion re: #203 MOTION to Disqualify Counsel . . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 218
***SELECTED PARTIES***DECLARATION of Nicole J. Moss in Opposition re: #203 MOTION to Disqualify Counsel .. Document filed by Virginia L. Giuffre, Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B)Motion or Order to File Under Seal: #200 .(Moss, Nicole)
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Filing 217
***SELECTED PARTIES*** RESPONSE in Opposition to Motion re: #203 MOTION to Disqualify Counsel . . Document filed by Virginia L. Giuffre, Alan Dershowitz. Motion or Order to File Under Seal: #200 .(Cooper, Charles)
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Filing 216
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 11/24/20 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days....(McGuirk, Kelly)
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Filing 215
TRANSCRIPT of Proceedings re: CONFERENCE held on 11/24/2020 before Judge Loretta A. Preska. Court Reporter/Transcriber: Paula Speer, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/21/2020. Redacted Transcript Deadline set for 12/31/2020. Release of Transcript Restriction set for 3/1/2021..(McGuirk, Kelly)
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Filing 214
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 11/24/2020 re: Follow-up from status conference. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 213
MEMO ENDORSEMENT on re: #212 Reply to Response to Motion, filed by Sharon Churcher. ENDORSEMENT: The Court will hold Ms. Churcher's request for a conference in abeyance pending further word from her. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/24/2020) (va)
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Minute Entry for proceedings held before Judge Loretta A. Preska: Interim Pretrial Conference held via Skype on 11/24/2020. The parties shall update the Court no later than December 22, 2020. (Court Reporter Paula Speer) (mph)
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Filing 212
LETTER REPLY to Response to Motion addressed to Judge Loretta A. Preska from Laura R. Handman dated November 23, 2020 re: #199 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. . Document filed by Sharon Churcher..(Handman, Laura)
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Filing 211
ORDER: The teleconference scheduled for November 24, 2020 at 2:30 p.m. EST (see dkt. nos. 191, 202) has been rescheduled to November 24, 2020 at 1:30 p.m. EST. The Court will communicate separately to counsel information for joining the teleconference. Members of the public may join the teleconference using the following listen-only line: (888) 3634734, access code: 4645450. SO ORDERED. ( Telephone Conference set for 11/24/2020 at 01:30 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 11/23/2020) (va)
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Filing 210
LETTER RESPONSE in Opposition to Motion addressed to Judge Loretta A. Preska from Howard M. Cooper dated November 20, 2020 re: #199 LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. . Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Kiely, Christian)
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Filing 209
LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated 11/19/2020 re: Response to #194 LETTER re Dispute Concerning Scope of Protective Order. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 208
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated November 19, 2020 re: Reply re: Dispute Concerning Scope of Protective Order. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 207
AFFIDAVIT of Christian G. Kiely in Support re: #203 MOTION to Disqualify Counsel .. Document filed by Alan Dershowitz. (Attachments: #1 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).(Kiely, Christian)
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Filing 206
MEMORANDUM OF LAW in Support re: #203 MOTION to Disqualify Counsel . Redacted Version. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 205
***SELECTED PARTIES***AFFIDAVIT of Christian G. Kiely in Support re: #203 MOTION to Disqualify Counsel .. Document filed by Alan Dershowitz, Virginia L. Giuffre. (Attachments: #1 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 or Order to File Under Seal: #200 .(Kiely, Christian)
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Filing 204
***SELECTED PARTIES*** MEMORANDUM OF LAW in Support re: #203 MOTION to Disqualify Counsel . . Document filed by Alan Dershowitz, Virginia L. Giuffre. Motion or Order to File Under Seal: #200 .(Kiely, Christian)
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Filing 203
MOTION to Disqualify Counsel . Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 202
ORDER: In advance of the teleconference scheduled for November 24, 2020 at 2:30 p.m. EST (see dkt. no. 191), the Court will communicate separately to counsel information for joining the teleconference. Members of the public may join the teleconference using the following listen-only line: (888) 363-4734, access code: 4645450. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/18/2020) (va)
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Filing 201
ORDER with respect to #199 Motion for Local Rule 37.2 Conference. The Court is in receipt of the letter from counsel to non party Sharon Churcher requesting a pre-motion conference (dkt. no. 199). Mr. Dershowitz shall provide a response to the letter no later than November 20, 2020. Ms. Churcher shall file any reply no later than November 23, 2020. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/18/2020) (va)
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Filing 200
ORDER granting #196 Letter Motion to Seal. Mr. Dershowitz's sealing request is granted. Ms. Giuffre also may file her response under seal to the extent it includes confidential or sealed material. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/18/2020) (nb)
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Set/Reset Deadlines: Responses due by 11/20/2020. Replies due by 11/23/2020. (va)
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Filing 199
LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Laura R. Handman dated 11/17/2020. Document filed by Sharon Churcher..(Handman, Laura)
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Filing 198
NOTICE OF APPEARANCE by Eric Joel Feder on behalf of Sharon Churcher..(Feder, Eric)
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Filing 197
NOTICE OF APPEARANCE by Laura R. Handman on behalf of Sharon Churcher..(Handman, Laura)
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Filing 196
LETTER MOTION to Seal Memorandum of Law and Certain Exhibits to Defendant's Motion to Disqualify Cooper & Kirk PLLC addressed to Judge Loretta A. Preska from Christian G. Kiely dated November 17, 2020. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 195
MEMO ENDORSEMENT on re: #192 Letter filed by Alan Dershowitz. ENDORSEMENT: The requested extension is approved. SO ORDERED. (Motions due by 11/18/2020.) (Signed by Judge Loretta A. Preska on 11/12/2020) (jca)
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Filing 194
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated November 12, 2020 re: Dispute Concerning Scope of Protective Order. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 193
LETTER MOTION for Discovery re Protective Order addressed to Judge Loretta A. Preska from Nicole J. Moss dated 11/12/2020. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A Draft Proposed Agreed Protective Order, #2 Exhibit B 12-16-19 Letter re Initial Disclosures).(Moss, Nicole)
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Filing 192
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated November 12, 2020 re: Briefing Schedule for Defendant's Motion to Disqualify. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 191
ORDER: The Court has reviewed the parties' letter dated November 5, 2020 addressing the status of discovery. (See dkt. no. 190.) The proposed briefing schedule addressing whether the documents produced by Plaintiff in Giuffre v. Maxwell under the protective order in that case should remain protected in this case is approved. The parties shall file initial letters no later than 5:00 p.m. EST on Thursday, November 12, and responsive letters no later than 5:00 p.m. on Thursday, November 19. Counsel for the parties shall appear for a telephonic conference on November 24, 2020 at 2:30 p.m. EST. The dial in for that conference is (888) 363-4734, access code: 4645450. SO ORDERED. ( Telephone Conference set for 11/24/2020 at 02:30 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 11/6/2020) (va)
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Filing 190
JOINT LETTER addressed to Judge Loretta A. Preska from Nicole J. Moss dated November 5, 2020 re: Joint Discovery Status Report. Document filed by Virginia L. Giuffre..(Moss, Nicole)
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Filing 189
MEMO ENDORSEMENT on re: #188 Letter filed by Alan Dershowitz. ENDORSEMENT: The briefing schedule proposed above is approved. SO ORDERED. (Motions due by 11/16/2020., Responses due by 12/4/2020, Replies due by 12/11/2020.) (Signed by Judge Loretta A. Preska on 10/30/2020) (js)
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Filing 188
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated October 30, 2020 re: Proposed Briefing Schedule for Defendant's Motion to Disqualify Counsel. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 187
ORDER: The Court has reviewed the parties' letters regarding Defendant Dershowitzs proposed motion to disqualify Ms. Giuffre's counsel. He may proceed with the motion. Counsel shall confer and inform the Court of the proposed briefing schedule. Counsel shall also confer and inform the Court by letter no later than November 5, 2020 of the status of discovery. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/28/2020) (va)
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Filing 186
SEALED DOCUMENT placed in vault..(jus)
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Filing 185
SEALED DOCUMENT placed in vault..(jus)
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Filing 184
SEALED DOCUMENT placed in vault..(jus)
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Filing 183
SEALED DOCUMENT placed in vault..(jus)
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Filing 182
SEALED DOCUMENT placed in vault..(jus)
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Filing 181
SEALED DOCUMENT placed in vault..(jus)
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Filing 180
SEALED DOCUMENT placed in vault..(jus)
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Filing 179
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated October 5, 2020 re: Reply re: Defendant's Request for Pre-Motion Conference Regarding Motion to Disqualify Cooper & Kirk PLLC. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 178
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 09/30/2020 re: Defendant's Request for Pre-Motion Conference Regarding Motion to Disqualify Cooper & Kirk PLLC. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1).(Cooper, Charles)
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Filing 177
ORDER re: #176 Letter, filed by Alan Dershowitz. The Court is in receipt of Defendant Alan Dershowitz's letter dated September 23, 2020, requesting that the Court hold a pre-motion conference at which Mr. Dershowitz will seek leave to file a motion to disqualify counsel for Plaintiff Virginia Giuffre, Cooper & Kirk. (See dkt. no. 176.) Ms. Giuffre shall respond by letter to Mr. Dershowitz's request no later than September 30, 2020. Mr. Dershowitz may reply no later than October 5, 2020. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/23/2020) (va)
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Filing 176
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated September 23, 2020 re: Defendant's Request for Pre-Motion Conference Regarding Motion to Disqualify Cooper & Kirk PLLC. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A).(Kiely, Christian)
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Filing 175
SEALED DOCUMENT placed in vault..(dn)
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Filing 174
ORDER re: (153 in 1:19-cv-03377-LAP) Letter filed by Alan Dershowitz. Mr. Dershowitz's request to modify the Maxwell protective order (dkt. no. 153) is granted in part and denied in part. Ms. Giuffre shall produce to Mr. Dershowitz all sealed materials and discovery that mentions Mr. Dershowitz, excluding material produced by or material (or portions of material) discussing a specific nonparty Doe whose privacy interests are the subject of a separate sealed order to be provided to Ms. Giuffre. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/9/2020) (va)
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Filing 173
ORDER: The Court has reviewed letters from Defendant Alan Dershowitz and Nonparties John Zeiger and Leslie Wexner regarding the Court's communications with Justice Goetz. (See dkt. nos. 169, 170.) First, it was not the Court's intention to discuss any substantive matters with Justice Goetz. Second, because he has not returned the Court's calls to his chambers, the matter is moot. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/1/2020) (va)
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Filing 172
ORDER: In an order dated August 4, 2020 (dkt. no. 1097 in 15 Civ. 7433), the Court invited any nonparties named in the sealed materials at issue in Giuffre v. Maxwell, No. 15 Civ. 7433, to submit to the Court for in camera review their comments on Defendant Alan Dershowitz's request in Giuffre v. Dershowitz, No. 19 Civ. 3377, that Plaintiff Virginia Giuffre produce to him confidential discovery materials and sealed filings from the Maxwell litigation. In that order, the Court noted that it would "at the least, inform the parties generally of the nature of any comments received." (Id. at 2.) The Court writes to provide that update. (As further set forth herein this Order.) (Signed by Judge Loretta A. Preska on 8/31/2020) (va)
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Filing 171
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari and Howard M. Cooper dated August 24, 2020 re: Alan Dershowitz's Response to Letter Filed by John Doe Dated August 19, 2020. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit Exhibit A).(Ansari, Imran)
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Filing 170
LETTER addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated August 21, 2020 re: Communications between Federal and State Courts. Document filed by Leslie H. Wexner, John W Zeiger..(Little, Marion)
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Filing 169
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated August 18, 2020 re: Communications between Federal and State Courts. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit Dershowitz Answer with Counterclaims without exhibits, #2 Exhibit Boies Summon and Complaint).(Ansari, Imran)
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Filing 168
STIPULATED PROTECTIVE ORDER...regarding procedures to be followed that shall govern the handling of confidential material... (Signed by Judge Loretta A. Preska on 8/18/2020) (va)
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Filing 167
PROPOSED PROTECTIVE ORDER. Document filed by Leslie H. Wexner, John W Zeiger..(Little, Marion)
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Filing 166
LETTER addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated August 17, 2020 re: Response to Offer of Proof [Doc. 164]. Document filed by Leslie H. Wexner, John W Zeiger. (Attachments: #1 Exhibit A - Excerpt of Dershowitz Deposition Transcript).(Little, Marion)
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Filing 165
ORDER: Certain Does have contacted the Court to request additional time to comment on the disclosure of sealed materials from Giuffre v. Maxwell, No. 15 Civ. 7433, to Alan Dershowitz, Defendant in Giuffre v. Dershowitz, No. 19 Civ. 3377, as discussed in the Court's Order dated August 4, 2020 [dkt. no. 154]. Accordingly, the Does shall submit comments about the proposed disclosure to the Court's email address at PreskaNYSDChambers@nysd.uscourts.gov by no later than August 25, 2020. No further extensions will be granted. SO ORDERED. (Signed by Judge Loretta A. Preska on 8/14/2020) (va)
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Filing 164
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated August 14, 2020 re: Offer of Proof Regarding Subpoenas to Leslie Wexner and John Zeiger. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B).(Kiely, Christian)
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Filing 163
ORDER FOR ADMISSION PRO HAC VICE granting #161 Motion for Marion H. Little, Jr. to Appear Pro Hac Vice. The motion of Marion H. Little, Jr. for admission to practice pro hac vice in the above caption matter is granted. (Signed by Judge Loretta A. Preska on 8/14/2020) (va)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #161 MOTION for Marion H. Little, Jr. to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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Filing 162
STATUS REPORT. (Joint) Re: Status of Negotiations as to Rule 45 Subpoenas to John Zeiger and Leslie Wexner Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 161
MOTION for Marion H. Little, Jr. to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Leslie H. Wexner, John W Zeiger. (Attachments: #1 Text of Proposed Order Order for Admission Pro Hac Vice).(Little, Marion)
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Filing 160
FILING ERROR - DEFICIENT DOCKET ENTRY -MOTION for Marion H. Little, Jr. to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21142459. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Leslie H. Wexner, John W Zeiger..(Little, Marion) Modified on 8/13/2020 (vba).
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #160 MOTION for Marion H. Little, Jr. to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-21142459. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Proposed Order;. Re-file the motion as a Corrected Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (vba)
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Filing 159
LETTER addressed to Judge Loretta A. Preska from Marion H. Little, Jr. dated July 28, 2020 re: [ #156 ] FIRST LETTER from Howard M. Cooper dated July 23, 2020 re: Rule 45 Subpoenas to Leslie Wexner and John Zeiger.. Document filed by Leslie H. Wexner. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C).(Petrillo, Guy)
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Filing 158
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 07/28/2020 re: Response to Defendant's Letter of July 23, 2020 Rule 45 Subpoenas to Leslie Wexner and John Zeiger. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 157
SECOND LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated July 31, 2020 re: Rule 45 Subpoenas to Leslie Wexner and John Zeiger. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 156
FIRST LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated July 23, 2020 re: Rule 45 Subpoenas to Leslie Wexner and John Zeiger. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F).(Kiely, Christian)
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Filing 155
ORDER: Accordingly, counsel for Mr. Dershowitz, Ms. Giuffre, and Mr. Wexner and Mr. Zeiger shall confer regarding Mr. Dershowitz's and Ms. Giuffre's requests and report to the Court by letter no later than August 13, 2020, the status of their discussions. Third, counsel for Mr. Dershowitz, Ms. Giuffre, and Mr. Wexner and Mr. Zeiger shall appear for a telephonic conference on August 17, 2020, at 2:00 p.m. EST. The Court will communicate separately to counsel information for joining the teleconference. Members of the media and the general public may join the teleconference using the following listen-only line: (888) 363-4734, access code: 4645450. SO ORDERED. (Signed by Judge Loretta A. Preska on 8/10/2020) (va)
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Set/Reset Hearings: Telephone Conference set for 8/17/2020 at 02:00 PM before Judge Loretta A. Preska. (va)
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Filing 154
ORDER: Accordingly, by posting this order both in Giuffre v. Maxwell, No. 15 Civ. 7433, and Giuffre v. Dershowitz, No. 19 Civ. 3377, the Court invites the Does to comment on the proposed disclosure. Any Doe who wishes to be heard on the disclosure proposed by counsel in Giuffre v. Dershowitz shall inform the Court of his/her views no later than August 18, 2020. Because those comments may discuss information that is currently under seal in Giuffre v. Maxwell, they will be submitted directly to the Court so that the Court can review them in camera. Comments may be sent to the Court's email address at PreskaNYSDChambers@nysd.uscourts.gov. The Court specifically requests comment from counsel for John Doe who has appeared in Maxwell. The Court will, at the least, inform the parties generally of the nature of any comments received. Relatedly, the parties request that the Court clarify that deposition transcripts and other documents not designated confidential on their face (excerpts of some of which were submitted under seal as part of the (now unsealed) summary judgment record in Maxwell, see infra n. 1) are not subject to the Maxwell Protective Order (dkt. no. 62 in 15 Civ. 7433) and thus may be freely disclosed and produced to Defendant without any restrictions on their use or disclosure. The Court agrees that materials not designated confidential are not covered by the Maxwell Protective Order but disagrees that there is necessarily no restriction on their disclosure. Specifically, certain materials may both (1) lack confidentiality designations made pursuant to the Protective Order and (2) be filed under seal in the Maxwell litigation. To the extent that the materials mention non-parties to the Maxwell action and remain under seal, such materials should not be disclosed before the non-parties mentioned are given notice and an opportunity to comment on the disclosure. (See supra at 2.) However, where such materials have already been unsealed--either by this Court or by the Court of Appeals--they may be freely disclosed. SO ORDERED. (Signed by Judge Loretta A. Preska on 8/4/2020) (va)
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Filing 153
JOINT LETTER addressed to Judge Loretta A. Preska from the Parties dated July 29, 2020 re: Court's July 22, 2020 Order (ECF No. 152). Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 152
ORDER with respect to #146 Letter Motion to Stay. Counsel shall report to the Court by letter no later than July 29, 2020, the status of their discussions. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/22/2020) (va)
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Filing 151
REPLY MEMORANDUM OF LAW in Support re: #136 MOTION to Dismiss Amended Counterclaims. . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 150
LETTER addressed to Judge Loretta A. Preska from Howard M. Cooper dated July 10, 2020 re: Reply to Response to Dershowitz Pre-Motion Letter of July 2, 2020. Document filed by Alan Dershowitz..(Kiely, Christian)
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Filing 149
DECLARATION of Charles J. Cooper in Opposition re: #146 LETTER MOTION to Stay re: #144 Order,,,, addressed to Judge Loretta A. Preska from Howard M. Cooper dated 07/02/2020.. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A- Email Exchange, #2 Exhibit B- Transcript, #3 Exhibit C- Subpoena, #4 Exhibit D- Email Exchange, #5 Exhibit E- Letter, #6 Exhibit F- Initial Disclosures, #7 Exhibit G- Plaintiff's Objections and Responses to Defendant's First Request for Production to Giuffre final (excerpts), #8 Exhibit H- Plaintiff's Objections and Responses to First Set of Interrogatories to Giuffre final (excerpts), #9 Exhibit I- Email Exchange, #10 Exhibit J- Email Exchange, #11 Exhibit K- Transcript).(Cooper, Charles)
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Filing 148
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated July 7, 2020 re: Dershowitz Pre-Motion Letter of July 2, 2020. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 147
ORDER with respect to #146 Letter Motion to Stay. The Court's July 1 order [dkt. no. 144] is hereby stayed pending further order of the Court. Ms. Giuffre shall respond to Mr. Dershowitz's requests by letter no later than July 7, 2020. Mr. Dershowitz shall reply to Ms. Giuffre no later than July 10,2020. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/6/2020) Copies Mailed By Chambers. (kv)
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Set/Reset Deadlines: Responses due by 7/7/2020 Replies due by 7/10/2020. (kv)
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Filing 146
LETTER MOTION to Stay re: #144 Order,,,, addressed to Judge Loretta A. Preska from Howard M. Cooper dated 07/02/2020. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 145
MEMORANDUM OF LAW in Opposition re: #136 MOTION to Dismiss Amended Counterclaims. . Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 144
MEMORANDUM & ORDER re: (133 in 1:19-cv-03377-LAP) FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated June 12, 2020, filed by Alan Dershowitz. For the reasons discussed above: (1) Cooper & Kirk shall destroy (a) all materials from Giuffre v. Maxwell, No. 15 Civ. 7433, currently in its possession, save for the transcript of Ms. Giuffre's deposition in that case and (b) all work product derived from the Maxwell materials. Cooper & Kirk shall submit to the Court an affidavit detailing the steps that it took to destroy the materials. In addition, to the extent it is doing so, Cooper & Kirk shall cease all use of the Maxwell materials--outside of Ms. Giuffre's deposition transcript--in its work on Ms. Giuffre's action against Mr. Dershowitz. (2) Mr. Dershowitz's request to modify the Maxwell Protective Order [dkt. no. 133 in 19 Civ. 3377] is denied. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/1/2020) (va)
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Minute Entry for proceedings held before Judge Loretta A. Preska: Telephone Conference held on 6/23/2020. (Court Reporter Khris Sellin) (mph)
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Filing 143
ORDER: Counsel for the parties in the above-captioned actions1 shall appear for a telephonic conference on June 23, 2020, at 2:00 p.m. EST. The dial-in for that conference is (888) 363-4734, access code: 4645450. The parties are directed to call in promptly at 2:00 p.m. SO ORDERED. ( Telephone Conference set for 6/23/2020 at 02:00 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 6/19/2020) (va)
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Filing 142
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated June 18, 2020 re: Defendant's Response to Plaintiff's letter dated June 17, 2020 re: Sealed Materials from Giuffre v. Maxwell, Case No. 15-cv-07433-LAP.. Document filed by Alan Dershowitz..(Ansari, Imran)
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Filing 141
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 06/17/2020 re: Sealed Materials from Giuffre v. Maxwell, Case No. 15-cv-07433-LAP. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 140
MEMO ENDORSEMENT on re: #135 Letter filed by Virginia L. Giuffre. ENDORSEMENT: The proposed briefing schedule is approved. SO ORDERED. ( Responses due by 7/2/2020, Replies due by 7/16/2020.) (Signed by Judge Loretta A. Preska on 6/16/2020) (va)
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Filing 139
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated June 15, 2020 re: Motion to Dismiss Amended Counterclaims. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 138
DECLARATION of Haley N. Proctor in Support re: #136 MOTION to Dismiss Amended Counterclaims.. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1 Complaint, #2 Exhibit 2 Amended Complaint, #3 Exhibit 3 Vol. I Am. Counterclaims and Exs., #4 Exhibit 3 Vol. II Am. Counterclaims and Exs.).(Cooper, Charles)
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Filing 137
MEMORANDUM OF LAW in Support re: #136 MOTION to Dismiss Amended Counterclaims. . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 136
MOTION to Dismiss Amended Counterclaims. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 135
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated June 15, 2020 re: Amended Counterclaims. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 134
ORDER: Plaintiff shall inform the Court by letter no later than June 17, 2020, of her views regarding Defendants letter dated June 12, 2020 [dkt. no. 133]. (Signed by Judge Loretta A. Preska on 6/15/2020) (cf)
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Filing 133
FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated June 12, 2020. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit Exhibit A, #2 Exhibit Exhibit B, #3 Exhibit Exhibit C, #4 Exhibit Exhibit D).(Cooper, Howard)
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Filing 132
ORDER re: #130 Letter filed by Virginia L. Giuffre. The Court has reviewed Plaintiff's letter regarding Defendant's amended counterclaims. (See dkt. no. 130.) Plaintiff's counsel shall inform the Court by letter no later than June 15, 2020, if Plaintiff wishes to 1) stand on her pending motion to dismiss, supplemented, if appropriate, by argument related to the newly-added material in the counterclaim, or 2) withdraw the present motion and file a new motion addressed to the amended counterclaim. Plaintiff's counsel shall inform Defendant's counsel and the Court of the course chosen, and, if appropriate, counsel shall confer and inform the Court of a proposed briefing schedule. SO ORDERED. (Signed by Judge Loretta A. Preska on 6/8/2020) (va)
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Filing 131
ORDER: The Court has reviewed the parties' letters regarding the scope of various subpoenas issued by Defendant to Plaintiff's current and prior counsel. (See dkt. nos. 125, 128, 129.) Defense counsel shall conclude negotiations with counsel for the law firms before asking the Court to intervene. SO ORDERED. (Signed by Judge Loretta A. Preska on 6/8/2020) (va)
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Filing 130
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated June 8, 2020 re: Amended Counterclaims. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 129
LETTER RESPONSE to Motion addressed to Judge Loretta A. Preska from Charles J. Cooper dated 06/05/2020 re: #125 FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated May 29, 2020. . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 128
LETTER RESPONSE to Motion addressed to Judge Loretta A. Preska from Michael A. Brille dated June 5, 2020 re: #125 FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated May 29, 2020. . Document filed by Boies Schiller Flexner LLP..(Weill, Richard)
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Filing 127
AMENDED COUNTERCLAIM amending #117 Amended Complaint against All Defendants.Document filed by Alan Dershowitz. Related document: #117 Amended Complaint. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P).(Oren, Kristine)
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Filing 126
ORDER re: #125 FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated May 29, 2020. filed by Alan Dershowitz. The Court is in receipt of Defendant Alan Dershowitz's request for a pre-motion conference on a motion to compel Boies Schiller Flexner LLP ("BSF") to produce documents requested in a Rule 45 subpoena that was served on BSF on December 5, 2019. (See dkt. no. 125.) BSF shall respond to Mr. Dershowitz's request no later than June 5, 2020. SO ORDERED. ( Responses due by 6/5/2020) (Signed by Judge Loretta A. Preska on 6/1/2020) (va)
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Filing 125
FIRST LETTER MOTION for Local Rule 37.2 Conference addressed to Judge Loretta A. Preska from Howard M. Cooper, Esq. dated May 29, 2020. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit Exhibit 1, #2 Exhibit Exhibit 2 Part 1, #3 Exhibit Exhibit 2 Part 2, #4 Exhibit Exhibit 2 Part 3, #5 Exhibit Exhibit 2 Part 4, #6 Exhibit Exhibit 2 Part 5, #7 Exhibit Exhibit 2 Part 6, #8 Exhibit Exhibit 3, #9 Exhibit Exhibit 4, #10 Exhibit Exhibit 5).(Cooper, Howard)
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Filing 124
ORDER granting #123 Letter Motion for Extension of Time to File Response/Reply re #119 MOTION to Dismiss Counterclaims. SO ORDERED. Responses due by 6/16/2020. Replies due by 6/30/2020. (Signed by Judge Loretta A. Preska on 5/28/2020) (va)
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Filing 123
JOINT LETTER MOTION for Extension of Time to File Response/Reply as to #119 MOTION to Dismiss Counterclaims. addressed to Judge Loretta A. Preska from Kristine C. Oren dated 05/27/2020. Document filed by Alan Dershowitz..(Oren, Kristine)
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Filing 122
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 05/19/2020 re: Motion To Dismiss Counterclaims. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 121
DECLARATION of Haley N. Proctor in Support re: #119 MOTION to Dismiss Counterclaims.. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1 Complaint, #2 Exhibit 2 Amended Complaint, #3 Exhibit 3 Answer with Counterclaims).(Cooper, Charles)
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Filing 120
MEMORANDUM OF LAW in Support re: #119 MOTION to Dismiss Counterclaims. . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 119
MOTION to Dismiss Counterclaims. Document filed by Virginia L. Giuffre. Responses due by 6/2/2020.(Cooper, Charles)
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Filing 118
ANSWER to #117 Amended Complaint with JURY DEMAND., COUNTERCLAIM against Virginia L. Giuffre. Document filed by Alan Dershowitz. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P).(Kiely, Christian)
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Filing 117
AMENDED COMPLAINT amending #116 Amended Complaint, #1 Complaint,, against Alan Dershowitz with JURY DEMAND.Document filed by Virginia L. Giuffre. Related document: #116 Amended Complaint, #1 Complaint,,..(Cooper, Charles)
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***NOTICE TO ATTORNEY REGARDING DEFICIENT PLEADING. Notice to Attorney Charles J Cooper to RE-FILE re: Document No. #116 Amended Complaint. The filing is deficient for the following reason(s): all of the parties listed on the pleading were not entered on CM ECF; the wrong filer/filers were selected for the pleading; Add Virginia Giuffre to CM ECF. Docket the event type Add Party to Pleading found under the event list Complaints and Other Initiating Documents.. Re-file the pleading using the event type Amended Complaint found under the event list Complaints and Other Initiating Documents - attach the correct signed PDF - select the individually named filer/filers - select the individually named party/parties the pleading is against. (pc)
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Filing 116
FILING ERROR - DEFICIENT PLEADING - FILER ERROR - AMENDED COMPLAINT amending #1 Complaint,, against Alan Dershowitz with JURY DEMAND.Document filed by Virginia L. Giuffre. Related document: #1 Complaint,,..(Cooper, Charles) Modified on 4/15/2020 (pc).
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Filing 115
MEMORANDUM & ORDER granting #99 Motion to Amend/Correct. For the reasons detailed above, Giuffre's motion to amend [dkt. no. 99] is GRANTED. To the extent not addressed in this opinion, the Court considered Dershowitz's remaining arguments and found them unavailing. Giuffre is directed to file her First Amended Complaint by no later than April 15, 2020. SO ORDERED. (Signed by Judge Loretta A. Preska on 4/8/2020) (va) (Main Document 115 replaced on 4/9/2020) (va). Modified on 4/9/2020 (va).
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Set/Reset Deadlines: Amended Pleadings due by 4/15/2020. (va)
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Filing 114
REPLY MEMORANDUM OF LAW in Support re: #99 MOTION to Amend/Correct #1 Complaint,, . . Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 113
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated February 7, 2020 re: Motion for Leave To File an Amended Complaint. Document filed by Virginia L. Giuffre..(Cooper, Charles)
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Filing 112
MEMORANDUM OF LAW in Opposition re: #99 MOTION to Amend/Correct #1 Complaint,, . . Document filed by Alan Dershowitz. (Oren, Kristine)
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Filing 111
MEMO ENDORSEMENT on re: #110 Letter, filed by Alan Dershowitz. ENDORSEMENT: Defendant may file an opposition of up to 25 pages. Plaintiff may have an additional five pages for her reply if necessary. SO ORDERED. (Signed by Judge Loretta A. Preska on 1/23/2020) (va)
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Filing 110
LETTER addressed to Judge Loretta A. Preska from Kristine C. Oren dated January 23, 2020 re: Request Pursuant to Individual Practice Rule 2.C Requesting Leave to File a Memorandum of Law of up to 25 Pages in Opposition to Plaintiff's Motion for Leave to File an Amended Complaint. Document filed by Alan Dershowitz.(Oren, Kristine)
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Filing 109
ORDER granting #108 Letter Motion for Extension of Time to File Response/Reply. SO ORDERED. Responses due by 1/24/2020 Replies due by 2/7/2020. (Signed by Judge Loretta A. Preska on 1/16/2020) (mml)
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Filing 108
AMENDED LETTER MOTION for Extension of Time to File Response/Reply as to #99 MOTION to Amend/Correct #1 Complaint,, . addressed to Judge Loretta A. Preska from Kristine C. Oren dated 1/16/2020. Document filed by Alan Dershowitz.(Oren, Kristine)
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Filing 107
JOINT LETTER MOTION for Extension of Time to File Response/Reply as to #99 MOTION to Amend/Correct #1 Complaint,, . addressed to Judge Loretta A. Preska from Kristine C. Oren dated 1/15/2020. Document filed by Alan Dershowitz.(Oren, Kristine)
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Filing 106
ORDER FOR ADMISSION PRO HAC VICE granting #105 Motion for Kristine Chappen Oren to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above-captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Loretta A. Preska on 1/3/2020) (mml)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #105 MOTION for Kristine Chappen Oren to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-18409777. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
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Filing 105
MOTION for Kristine Chappen Oren to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-18409777. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alan Dershowitz. (Attachments: #1 Affidavit, #2 Exhibit Certificates of Good Standing, #3 Text of Proposed Order)(Oren, Kristine)
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Filing 104
AGREED ORDER: Based on the parties agreement, it is hereby ORDERED that the microcassette tape produced by Defendant to Stroz Friedberg and currently in Stroz Friedberg's possession shall be promptly turned over to the forensic firm of CDS Legal for whatever analysis either party requests and pays for. SO ORDERED. (Signed by Judge Loretta A. Preska on 12/23/2019) (va)
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Filing 103
LETTER addressed to Judge Loretta A. Preska from Christian G. Kiely dated December 23, 2019 re: Plaintiff's Motion for Leave to File an Amended Complaint. Document filed by Alan Dershowitz.(Kiely, Christian)
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Filing 102
JOINT LETTER addressed to Judge Loretta A. Preska from Counsel dated 12/23/2019 re: Audio Recording. Document filed by Virginia L. Giuffre. (Attachments: #1 Text of Proposed Order Proposed Agreed Order)(Cooper, Charles)
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Filing 101
AFFIDAVIT of Haley N. Proctor in Support re: #99 MOTION to Amend/Correct #1 Complaint,, .. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit Exhibit A Proposed Amended Complaint, #2 Exhibit Exhibit B Redlined Proposed Amended Complaint, #3 Exhibit Exhibit C Transcript)(Cooper, Charles)
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Filing 100
MEMORANDUM OF LAW in Support re: #99 MOTION to Amend/Correct #1 Complaint,, . . Document filed by Virginia L. Giuffre. (Cooper, Charles)
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Filing 99
MOTION to Amend/Correct #1 Complaint,, . Document filed by Virginia L. Giuffre.(Cooper, Charles)
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Filing 98
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated December 20, 2019 re: Motion for Leave to File an Amended Complaint. Document filed by Virginia L. Giuffre.(Cooper, Charles)
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Filing 97
NOTICE OF FILING OF OFFICIAL TRANSCRIPT Notice is hereby given that an official transcript of a CONFERENCE proceeding held on 12/2/19 has been filed by the court reporter/transcriber in the above-captioned matter. The parties have seven (7) calendar days to file with the court a Notice of Intent to Request Redaction of this transcript. If no such Notice is filed, the transcript may be made remotely electronically available to the public without redaction after 90 calendar days...(McGuirk, Kelly)
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Filing 96
TRANSCRIPT of Proceedings re: CONFERENCE held on 12/2/2019 before Judge Loretta A. Preska. Court Reporter/Transcriber: Karen Gorlaski, (212) 805-0300. Transcript may be viewed at the court public terminal or purchased through the Court Reporter/Transcriber before the deadline for Release of Transcript Restriction. After that date it may be obtained through PACER. Redaction Request due 12/31/2019. Redacted Transcript Deadline set for 1/10/2020. Release of Transcript Restriction set for 3/9/2020.(McGuirk, Kelly)
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Filing 95
STIPULATION AND ORDER: IT IS HEREBY STIPULATED AND AGREED by and between the undersigned attorneys for the parties that the time within which Plaintiff Virginia L. Giuffre may move, answer, or otherwise respond to Defendant Alan Dershowitz's counterclaims is hereby extended up to and including: (1) December 20, 2019, if Plaintiff elects not to move to amend the Complaint on or before that date, (2) if Plaintiff moves to amend the Complaint and the Court denies such motion, 21 days after the Court enters the denial, or (3) if the Court grants a motion to amend the Complaint, 21 days after Defendant serves his amended answer and counterclaims. The parties further stipulate that Defendant's time to respond to a motion to amend the Complaint or to dismiss the counterclaims, filed on or before December 20, 2019, is hereby extended up to and including January 17, 2020. No provision of this Stipulation and Order shall be construed as a waiver of, and Plaintiff expressly reserves, any and all defenses. The original deadline for Plaintiff to move, answer, or otherwise respond to the counterclaims was November 29, 2019. There has been no previous request for extension of time in connection with Plaintiff's response to the counterclaims or Defendant's response to a motion to amend the Complaint or to dismiss the counterclaims. Virginia L. Giuffre answer due 12/20/2019. (Motions due by 12/30/2019., Responses due by 1/17/2020.) (Signed by Judge Loretta A. Preska on 11/25/2019) (mml)
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Filing 94
PROPOSED STIPULATION AND ORDER. Document filed by Virginia L. Giuffre. (Proctor, Haley)
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Filing 93
RULE 26(f) DISCOVERY PLAN REPORT.Document filed by Virginia L. Giuffre.(Moss, Nicole)
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Filing 92
JOINT LETTER addressed to Judge Loretta A. Preska from Counsel dated 11/20/2019 re: Electronic Device Request. Document filed by Virginia L. Giuffre. (Attachments: #1 Text of Proposed Order)(Proctor, Haley)
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Filing 91
ORDER: In advance of the conference scheduled for December 2, 2019, counsel shall submit their discovery plan by no later than 12:00 pm on Wednesday, November 27, 2019. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/15/2019) (mml)
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Filing 90
ANSWER to #1 Complaint,, with JURY DEMAND., COUNTERCLAIM against Virginia L. Giuffre. Document filed by Alan Dershowitz. (Attachments: #1 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, #10 Exhibit J, #11 Exhibit K, #12 Exhibit L, #13 Exhibit M, #14 Exhibit N, #15 Exhibit O, #16 Exhibit P)(Kiely, Christian)
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Filing 89
ORDER: The Court has conferred with counsel for both parties. The currently scheduled conference will remain on December 2, 2019 at 9:00 AM. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/6/2019) (mml)
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Filing 88
ORDER FOR ADMISSION PRO HAC VICE granting #87 Motion for Nicole Jo Moss to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Loretta A. Preska on 11/6/2019) (mml)
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Filing 87
MOTION for Nicole Jo Moss to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17897934. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Virginia L. Giuffre. (Attachments: #1 Affidavit Declaration of Nicole J. Moss, #2 Exhibit Maryland Certificate of Good Standing, #3 Exhibit North Carolina Certificate of Good Standing, #4 Exhibit DC Certificate of Good Standing, #5 Text of Proposed Order For Admission Pro Hac Vice)(Moss, Nicole)
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Filing 86
ORDER: Because Plaintiff has engaged new counsel, counsel shall confer with each other and with the Court's deputy regarding a date earlier than December 2 for a conference and shall submit their discovery plan in advance of the conference. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/5/2019) (mml)
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Filing 85
ORDER denying #71 Letter Motion for Local Rule 37.2 Conference. Defendant's request for pre-Answer discovery is denied on the following grounds: 1. Defendant has not made any showing that pre-Answer discovery is necessary - and not just helpful - to his preparation of an Answer and/or Counterclaims. 2. Defendant has not provided the Court with any justification for departing from the Court-ordered unsealing process in Giuffre v. Maxwell. SO ORDERED. (Signed by Judge Loretta A. Preska on 11/5/2019) (mml)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #87 MOTION for Nicole Jo Moss to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17897934. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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Filing 84
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated 11/04/2019 re: Pre-Answer Discovery and Audio Recording. Document filed by Virginia L. Giuffre.(Cooper, Charles)
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Filing 83
ORDER FOR ADMISSION PRO HAC VICE granting #78 Motion for Haley Marie Nix Proctor to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Loretta A. Preska on 11/4/2019) (mml)
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Filing 82
ORDER FOR ADMISSION PRO HAC VICE granting #77 Motion for Michael William Kirk to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Loretta A. Preska on 11/4/2019) (mml)
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Filing 81
ORDER FOR ADMISSION PRO HAC VICE granting #76 Motion for Charles Justin Cooper to Appear Pro Hac Vice. IT IS HEREBY ORDERED that Applicant is admitted to practice Pro Hac Vice in the above captioned case in the United States District Court for the Southern District of New York. All attorneys appearing before this Court are subject to the Local Rules of this Court, including the Rules governing discipline of attorneys. (Signed by Judge Loretta A. Preska on 11/4/2019) (mml)
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Filing 80
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari, Esq. dated 11/4/19 re: Reply/Response to Letter Filed by Plaintiff re: Audio Recording. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 79
LETTER addressed to Judge Loretta A. Preska from Charles J. Cooper dated November 1, 2019 re: Audio Recording. Document filed by Virginia L. Giuffre.(Cooper, Charles)
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Filing 78
MOTION for Haley Marie Nix Proctor to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17869086. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Virginia L. Giuffre. (Attachments: #1 Affidavit Declaration of Haley N. Proctor, #2 Exhibit Oklahoma Certificate of Good Standing, #3 Exhibit Virginia Certificate of Good Standing, #4 Exhibit DC Certificate of Good Standing, #5 Text of Proposed Order For Admission Pro Hac Vice)(Proctor, Haley)
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Filing 77
MOTION for Michael William Kirk to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17868876. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Virginia L. Giuffre. (Attachments: #1 Affidavit Declaration of Michael W. Kirk, #2 Exhibit New York Certificate of Good Standing, #3 Exhibit DC Certificate of Good Standing, #4 Text of Proposed Order For Admission Pro Hac Vice)(Kirk, Michael)
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Filing 76
MOTION for Charles Justin Cooper to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17868673. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Virginia L. Giuffre. (Attachments: #1 Affidavit Declaration of Charles J. Cooper, #2 Exhibit Alabama Certificate of Good Standing, #3 Exhibit Georgia Certificate of Good Standing, #4 Exhibit DC Certificate of Good Standing, #5 Text of Proposed Order For Admission Pro Hac Vice)(Cooper, Charles)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #76 MOTION for Charles Justin Cooper to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17868673. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #77 MOTION for Michael William Kirk to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17868876. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #78 MOTION for Haley Marie Nix Proctor to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17869086. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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Filing 75
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/30/19 re: Response to Letter Filed by John Doe. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 74
MEMO ENDORSEMENT on re: #73 Letter filed by Alan Dershowitz. ENDORSEMENT: Defendant's time to serve a responsive pleading is extended to November 7. To avoid further delay, counsel shall confer with plaintiff's current counsel on this rather ministerial matter. SO ORDERED. Alan Dershowitz answer due 11/7/2019. (Signed by Judge Loretta A. Preska on 10/30/2019) (mml)
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Filing 73
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/30/2019 re: Request for Extension of Time to File Answer and Counterclaims. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 72
ORDER with respect to #71 Letter Motion for Local Rule 37.2 Conference. Counsel shall confer with Plaintiff's counsel. If Plaintiff's counsel disagrees, he or she may inform the Court by letter no later than November 4. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/25/2019) (ks) Modified on 11/26/2019 (ks).
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Filing 71
LETTER MOTION for Local Rule 37.2 Conference re: Pre-Answer Discovery addressed to Judge Loretta A. Preska from Howard M. Cooper dated October 24, 2019. Document filed by Alan Dershowitz. Return Date set for 10/29/2019 at 05:00 PM. (Attachments: #1 Exhibit A)(Kiely, Christian)
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Filing 70
MEMO ENDORSEMENT on re: #69 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Initial Conference set for 12/2/2019 at 02:00 PM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 10/23/2019) (mml)
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Filing 69
FIRST LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/18/19 re: Request for Adjournment of November 20, 2019 Rule 16 Conference. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 68
SEALED DOCUMENT placed in vault.(mhe)
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Filing 67
OPINION AND ORDER: re: #7 MOTION to Disqualify Counsel for Plaintiff. filed by Alan Dershowitz, #22 MOTION to Dismiss Complaint. filed by Alan Dershowitz. Defendant's motion to dismiss the complaint [dkt. no. 22] is denied. Defendant's motion to disqualify the law firm of Boies Schiller Flexner LLP [dkt. no. 7] is granted. New counsel for Plaintiff and counsel for Defendant shall confer and submit a proposed discovery plan no later than November 13. Counsel shall appear for a Rule 16 conference on November 20 at 11:00 A.M. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/16/2019) (js)
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Set/Reset Hearings: Initial Conference set for 11/20/2019 at 11:00 AM before Judge Loretta A. Preska. (js)
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Filing 66
MEMO ENDORSEMENT on re: #65 Letter filed by Alan Dershowitz. ENDORSEMENT: Prof. Dershowitz shall forthwith turn over the microcassette to the Stroz Friedberg firm for whatever analysis the parties order and pay for. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/10/2019) (mml)
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Filing 65
LETTER addressed to Judge Loretta A. Preska from Imran H. Ansari dated October 10, 2019 re: Audio Recording. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 64
LETTER addressed to Judge Loretta A. Preska from Sigrid McCawley dated October 3, 2019 re: Response to Defendant Letter (DE 61). Document filed by Virginia L. Giuffre.(McCawley, Sigrid)
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Filing 63
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/03/19 re: Correction to Post-Argument Letter. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 62
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/03/19 re: * TITLE CORRECTION* Post Argument Letter re: Motion to Disqualify AND MOTION TO DISMISS. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 61
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/03/2019 re: Post Argument Letter re: Motion to Disqualify. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 60
MEMO ENDORSEMENT on re: #54 Letter filed by Alan Dershowitz. ENDORSEMENT: Counsel may submit a three-page, double spaced letter in 12-point type no later that October 3 at 9:00am. Plaintiff may submit a similar letter no later than 5:00pm on October 4. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/2/2019) (mml)
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Filing 59
SECOND LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/01/2019 re: Reply in Support of Request for Leave to File a Post-Argument Submission. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 58
LETTER addressed to Judge Loretta A. Preska from Sigrid McCawley dated October 1, 2019 re: Plaintiff's Objection to DE 54. Document filed by Virginia L. Giuffre.(McCawley, Sigrid)
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Filing 57
MEMO ENDORSEMENT on re: #55 Letter filed by Alan Dershowitz. ENDORSEMENT: Denied. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/1/2019) (mml)
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Filing 56
ORDER: Defendant's counsel shall forthwith turn over the tape recording of Mr. Boies discussed at last week's oral argument to Stroz Friedberg or a similar digital forensic firm for whatever analysis either party requests and pays for. The digital forensic firm shall forthwith produce a copy of the tape recording to counsel for each party. SO ORDERED. (Signed by Judge Loretta A. Preska on 10/1/2019) (mml)
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Filing 55
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/01/2019 re: Objection to Release of Audio Tape. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 54
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 10/01/2019 re: Request for Leave to File a Post-Argument letter to Clarify and Provide Factual Information. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 53
LETTER addressed to Judge Loretta A. Preska from Sigrid McCawley dated September 26, 2019 re: Sealed Document DE 50. Document filed by Virginia L. Giuffre.(McCawley, Sigrid)
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Filing 52
SEALED DOCUMENT placed in vault.(rz)
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Filing 51
MEMO ENDORSEMENT on re: #50 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 9/25/2019) (mml)
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Filing 50
FIRST LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated September 25, 2019 re: Request for Order to File Documents Under Seal Pursuant to Sept 24, 2019 hearing. Document filed by Alan Dershowitz.(Ansari, Imran)
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Minute Entry for proceedings held before Judge Loretta A. Preska: Oral Argument held on 9/24/2019 re: #7 MOTION to Disqualify Counsel for Plaintiff. filed by Alan Dershowitz, #22 MOTION to Dismiss Complaint. filed by Alan Dershowitz. (Court Reporter Karen Gorlaski) (mph)
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Filing 49
ORDER: It is the Court's intention to hold a separate argument with respect to the Confidential Memorandum referred to in this Court's July 17, 2019 order [dkt. no. 41]. The Court will ask Professor Dershowitz how disclosure of the Memorandum to the Boise Schiller Firm ("BSF") could result in any detriment to him and will ask BSF to specify how the contents of the Memorandum have been made public. The Court is willing to meet separately with the parties, if necessary. SO ORDERED. (Signed by Judge Loretta A. Preska on 9/18/2019) (mml) Modified on 9/18/2019 (mml).
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Filing 48
SCHEDULING ORDER: It is hereby ORDERED that the oral argument scheduled for September 24, 2019 at 9:00 a.m. is adjourned to September 24, 2019 at 10:00 a.m. SO ORDERED. Oral Argument set for 9/24/2019 at 10:00 AM before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 9/18/2019) (mml)
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Filing 47
ORDER granting #46 Letter Motion to Adjourn Conference: The argument is adjourned to September 24 at 9:0am in Courtroom 12A. (Oral Argument set for 9/24/2019 at 09:00 AM in Courtroom 12A, 500 Pearl Street, New York, NY 10007 before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 9/5/2019) (jwh)
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Filing 46
SECOND LETTER MOTION to Adjourn Conference Motion to Dismiss and Motion to Disqualify addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 9/5/19. Document filed by Alan Dershowitz. Return Date set for 9/11/2019 at 11:00 AM.(Ansari, Imran)
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Filing 45
MEMO ENDORSEMENT on re: #44 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Oral Argument set for 9/11/2019 at 11:00 AM before Judge Loretta A. Preska.) (Signed by Judge Loretta A. Preska on 8/15/2019) (mml)
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Filing 44
FIRST LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated 8/14/19 re: Oral argument adjournment. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 43
ORDER: Counsel shall appear for oral argument on the motion to disqualify and the motion to dismiss on September 9, 2019 at 10:00 a.m. in courtroom 12A. SO ORDERED. Oral Argument set for 9/9/2019 at 10:00 AM in Courtroom 12A, 500 Pearl Street, New York, NY 10007 before Judge Loretta A. Preska. (Signed by Judge Loretta A. Preska on 8/5/2019) (mml)
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Filing 42
SEALED DOCUMENT placed in vault.(mhe)
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Filing 41
ORDER re: #39 Reply Memorandum of Law in Support of Motion, filed by Alan Dershowitz. Pursuant to footnote 5 of his reply brief on the motion to disqualify [dkt. no. 39], Defendant is directed to file the Confidential Memorandum under seal for the Court's in camera review. SO ORDERED. (Signed by Judge Loretta A. Preska on 7/17/2019) (kv)
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Filing 40
REPLY MEMORANDUM OF LAW in Support re: #22 MOTION to Dismiss Complaint. . Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A)(Cooper, Howard)
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Filing 39
REPLY MEMORANDUM OF LAW in Support re: #7 MOTION to Disqualify Counsel for Plaintiff. . Document filed by Alan Dershowitz. (Attachments: #1 Exhibit FIRST SUPPLEMENTAL DECLARATION OF ALAN DERSHOWITZ, #2 Exhibit EMAIL FROM SIRES TO DERSHOWITZ, #3 Exhibit EMAIL FROM SIRES TO DERSHOWITZ, #4 Exhibit DAILY MAIL ARTICLE)(Ansari, Imran)
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Filing 38
MEMORANDUM OF LAW in Opposition re: #22 MOTION to Dismiss Complaint. . Document filed by Virginia L. Giuffre. (Schiller, Joshua)
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Filing 37
ORDER FOR ADMISSION PRO HAC VICE granting #30 Motion for Sigrid S. McCawley to Appear Pro Hac Vice. (Signed by Judge Loretta A. Preska on 7/3/2019) (jwh)
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Filing 36
DECLARATION of Joshua I. Schiller in Opposition re: #7 MOTION to Disqualify Counsel for Plaintiff.. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit 1, #2 Exhibit 2, #3 Exhibit 3, #4 Exhibit 4, #5 Exhibit 5, #6 Exhibit 6, #7 Exhibit 7, #8 Exhibit 8, #9 Exhibit 9, #10 Exhibit 10, #11 Exhibit 11, #12 Exhibit 12, #13 Exhibit 13, #14 Exhibit 14, #15 Exhibit 15, #16 Exhibit 16)(Schiller, Joshua)
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Filing 35
DECLARATION of David Boies in Opposition re: #7 MOTION to Disqualify Counsel for Plaintiff.. Document filed by Virginia L. Giuffre. (Schiller, Joshua)
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Filing 34
DECLARATION of Prof. Roy D. Simon, Jr. in Opposition re: #7 MOTION to Disqualify Counsel for Plaintiff.. Document filed by Virginia L. Giuffre. (Attachments: #1 Exhibit A)(Schiller, Joshua)
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Filing 33
MEMORANDUM OF LAW in Opposition re: #7 MOTION to Disqualify Counsel for Plaintiff. . Document filed by Virginia L. Giuffre. (Schiller, Joshua)
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Filing 32
MEMO ENDORSEMENT on re: #31 Letter filed by Virginia L. Giuffre. ENDORSEMENT: SO ORDERED. (Signed by Judge Loretta A. Preska on 7/3/2019) (kv)
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Filing 31
LETTER addressed to Judge Loretta A. Preska from Joshua I. Schiller dated July 2, 2019 re: Length of Memorandum of Law in Opposition to Motion to Disqualify. Document filed by Virginia L. Giuffre.(Schiller, Joshua)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #30 MOTION for Sigrid S. McCawley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17176235. Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (jc)
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Filing 30
MOTION for Sigrid S. McCawley to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17176235. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Virginia L. Giuffre. (Attachments: #1 Affidavit Declaration, #2 Exhibit COGS, #3 Text of Proposed Order Proposed Order)(McCawley, Sigrid)
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Filing 29
ORDER FOR ADMISSION PRO HAC VICE granting #27 Motion for Christian G. Kiely to Appear Pro Hac Vice. (Signed by Judge Loretta A. Preska on 6/27/2019) (jca)
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Filing 28
ORDER FOR ADMISSION PRO HAC VICE granting #26 Motion for Howard M. Cooper to Appear Pro Hac Vice. (Signed by Judge Loretta A. Preska on 6/26/2019) (rjm)
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Filing 27
MOTION for Christian G. Kiely to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alan Dershowitz. (Attachments: #1 Affidavit of Christian G. Kiely, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order for Admission)(Kiely, Christian)
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Filing 26
MOTION for Howard M. Cooper to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alan Dershowitz. (Attachments: #1 Affidavit of Howard M. Cooper, #2 Exhibit Certificate of Good Standing, #3 Text of Proposed Order Proposed Order for Admission)(Cooper, Howard)
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>>>NOTICE REGARDING DEFICIENT MOTION TO APPEAR PRO HAC VICE. Notice to RE-FILE Document No. #25 MOTION for Christian G. Kiely to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17138926. Motion and supporting papers to be reviewed by Clerk's Office staff., #21 MOTION for Howard M. Cooper to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17138693. Motion and supporting papers to be reviewed by Clerk's Office staff... The filing is deficient for the following reason(s): missing Certificate of Good Standing from Supreme Court of Massachusetts; missing Proposed Order;. Re-file the motion as a Motion to Appear Pro Hac Vice - attach the correct signed PDF - select the correct named filer/filers - attach valid Certificates of Good Standing issued within the past 30 days - attach Proposed Order.. (wb)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #27 MOTION for Christian G. Kiely to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (bcu)
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>>>NOTICE REGARDING PRO HAC VICE MOTION. Regarding Document No. #26 MOTION for Howard M. Cooper to Appear Pro Hac Vice . Motion and supporting papers to be reviewed by Clerk's Office staff.. The document has been reviewed and there are no deficiencies. (wb)
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Filing 25
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Christian G. Kiely to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17138926. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alan Dershowitz. (Attachments: #1 Affidavit of Christian G. Kiely)(Kiely, Christian) Modified on 6/26/2019 (wb).
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Filing 24
DECLARATION of Michelle Proctus in Support re: #22 MOTION to Dismiss Complaint.. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit A, #2 Exhibit B, #3 Exhibit C, #4 Exhibit D, #5 Exhibit E, #6 Exhibit F, #7 Exhibit G, #8 Exhibit H)(Cooper, Howard)
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Filing 23
MEMORANDUM OF LAW in Support re: #22 MOTION to Dismiss Complaint. . Document filed by Alan Dershowitz. (Cooper, Howard)
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Filing 22
MOTION to Dismiss Complaint. Document filed by Alan Dershowitz. Responses due by 7/9/2019(Cooper, Howard)
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Filing 21
FILING ERROR - DEFICIENT DOCKET ENTRY - MOTION for Howard M. Cooper to Appear Pro Hac Vice . Filing fee $ 200.00, receipt number ANYSDC-17138693. Motion and supporting papers to be reviewed by Clerk's Office staff. Document filed by Alan Dershowitz. (Attachments: #1 Affidavit of Howard M. Cooper)(Cooper, Howard) Modified on 6/26/2019 (wb).
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Filing 20
ORDER granting #19 FIRST LETTER MOTION for Leave to File Excess Pages for Memorandum of Law in Support of a Motion to Dismiss the Complaint addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated June 25, 2019. Document filed by Alan Dershowitz. So ordered. (Signed by Judge Loretta A. Preska on 6/25/2019) (rjm)
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Filing 19
FIRST LETTER MOTION for Leave to File Excess Pages for Memorandum of Law in Support of a Motion to Dismiss the Complaint addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated June 25, 2019. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 18
MEMO ENDORSEMENT on re: #17 Letter filed by Alan Dershowitz. ENDORSEMENT: SO ORDERED. (Set Deadlines/Hearing as to #7 MOTION to Disqualify Counsel for Plaintiff: Responses due by 7/3/2019, Replies due by 7/10/2019.) (Signed by Judge Loretta A. Preska on 6/19/2019) (jwh)
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Filing 17
LETTER addressed to Judge Loretta A. Preska from Imran Ansari, Esq. dated June 19, 2019 re: Motion Briefing Schedule. Document filed by Alan Dershowitz.(Ansari, Imran)
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Filing 16
ORDER re: #15 Letter filed by Virginia L. Giuffre: Following review of Mr. Schiller's letter dated June 17, 2019 [dkt no. 15], it is hereby ordered that: 1) Mr. Dershowitz is excused from the requirement for a premotion conference on the Court's finding that such a conference would be futile; 2) Mr. Dershowitz's motion to disqualify the Boise Schiller firm [dkt. nos. 7-11] is reinstated to the calendar; 3) Mr. Dershowitz may file a memorandum of law of 28 pages; and 4) Counsel shall confer and inform the Court by letter of the proposed briefing schedule. (Signed by Judge Loretta A. Preska on 6/17/2019) (jwh)
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Filing 15
LETTER addressed to Judge Loretta A. Preska from Joshua I. Schiller dated June 17, 2019 re: Request for Pre-Motion Conference re: Defendant's Motion to Disqualify Counsel for Plaintiff. Document filed by Virginia L. Giuffre.(Schiller, Joshua)
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Filing 14
FIRST LETTER addressed to Judge Loretta A. Preska from Arthur L. Aidala dated June 12, 2019 re: Request for Pre-Motion Conference re: Defendant's Motion to Disqualify Counsel for Plaintiff. Document filed by Alan Dershowitz.(Aidala, Arthur)
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Filing 13
MEMO ENDORSEMENT on: #12 LETTER terminating #7 Motion to Disqualify Counsel. ENDORSEMENT: Mr. Dershowitz's motion to disqualify [dkt. no. 8-10] is marked off the calendar for failure to comply with the Court's Individual Practice Rule. 2.1. (Signed by Judge Loretta A. Preska on 6/11/2019) (jwh)
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Filing 12
LETTER addressed to Judge Loretta A. Preska from Joshua I. Schiller dated 6/11/2019 re: Defendant Dershowitz's Motion to Disqualify. Document filed by Virginia L. Giuffre.(Schiller, Joshua)
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Filing 11
PROPOSED ORDER. Document filed by Alan Dershowitz. Related Document Number: #7 . (Aidala, Arthur) Proposed Order to be reviewed by Clerk's Office staff.
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Filing 10
DECLARATION of Alan Dershowitz in Support re: #7 MOTION to Disqualify Counsel for Plaintiff.. Document filed by Alan Dershowitz. (Attachments: #1 Exhibit SDNY Complaint, #2 Exhibit Letter to BSF, #3 Exhibit Email from Schiller, #4 Exhibit Daily Mail Article, #5 Exhibit Freeh's Report, #6 Exhibit Cassell and Edwards Statement, #7 Exhibit Decision of Judge Marra, #8 Exhibit Emails btwn Dershowitz and Sires, #9 Exhibit Gravante Letter, #10 Exhibit McMahon Decision)(Aidala, Arthur)
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Filing 9
DECLARATION of Bruce A. Green in Support re: #7 MOTION to Disqualify Counsel for Plaintiff.. Document filed by Alan Dershowitz. (Attachments: #1 CV of Bruce Green)(Aidala, Arthur)
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Filing 8
MEMORANDUM OF LAW in Support re: #7 MOTION to Disqualify Counsel for Plaintiff. . Document filed by Alan Dershowitz. (Aidala, Arthur)
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Filing 7
MOTION to Disqualify Counsel for Plaintiff. Document filed by Alan Dershowitz. (Attachments: #1 CERTIFICATE OF SERVICE)(Aidala, Arthur)
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Filing 6
NOTICE OF APPEARANCE by Arthur Louis Aidala on behalf of Alan Dershowitz. (Aidala, Arthur)
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Filing 5
NOTICE OF APPEARANCE by Imran H. Ansari on behalf of Alan Dershowitz. (Ansari, Imran)
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***NOTICE TO COURT REGARDING PROPOSED ORDER. Document No. #11 Proposed Order was reviewed and approved as to form. (dt)
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Filing 4
ELECTRONIC SUMMONS ISSUED as to Alan Dershowitz. (pc)
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***NOTICE TO ATTORNEY REGARDING PARTY MODIFICATION. Notice to attorney Joshua Schiller. The party information for the following party/parties has been modified: VIRGINIA L. GIUFFRE, Alan M. Dershowitz. The information for the party/parties has been modified for the following reason/reasons: party name contained a typographical error; party name was entered in all caps; party role was entered incorrectly;. (pc)
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***NOTICE TO ATTORNEY REGARDING CIVIL. CASE OPENING STATISTICAL ERROR CORRECTION: Notice to attorney Joshua Schiller. The following case opening statistical information was erroneously selected/entered: Citizenship Plaintiff code 2 (Citizen of Another State); Dollar Demand $75,000,000; County code New York;. The following correction(s) have been made to your case entry: the Citizenship Plaintiff code has been modified to 3 (Citizen or Subject of a Foreign Country); the Dollar Demand has been modified to blank; the County code has been modified to XX Out of U.S.;. (pc)
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CASE OPENING INITIAL ASSIGNMENT NOTICE: The above-entitled action is assigned to Judge Loretta A. Preska. Please download and review the Individual Practices of the assigned District Judge, located at #http://nysd.uscourts.gov/judges/District. Attorneys are responsible for providing courtesy copies to judges where their Individual Practices require such. Please download and review the ECF Rules and Instructions, located at #http://nysd.uscourts.gov/ecf_filing.php. (pc)
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Magistrate Judge Sarah Netburn is so designated. Pursuant to 28 U.S.C. Section 636(c) and Fed. R. Civ. P. 73(b)(1) parties are notified that they may consent to proceed before a United States Magistrate Judge. Parties who wish to consent may access the necessary form at the following link: #http://nysd.uscourts.gov/forms.php. (pc)
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Case Designated ECF. (pc)
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Filing 3
CIVIL COVER SHEET filed. (Schiller, Joshua)
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Filing 2
REQUEST FOR ISSUANCE OF SUMMONS as to ALAN DERSHOWITZ, re: #1 Complaint,,. Document filed by VIRGINIA L. GIUFFRE. (Schiller, Joshua)
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Filing 1
COMPLAINT against Alan M. Dershowitz. (Filing Fee $ 400.00, Receipt Number ANYSDC-16706500)Document filed by VIRGINIA L. GIUFFRE. (Attachments: #1 Exhibit 1_Article, #2 Exhibit 2_Article, #3 Exhibit 3_Article, #4 Exhibit 4_Article, #5 Exhibit 5_Article, #6 Exhibit 6_Social Media Post, #7 Exhibit 7_Letter, #8 Exhibit 8_Article, #9 Exhibit 9_Article, #10 Exhibit 10_Article, #11 Exhibit 11_Article, #12 Exhibit 12_Affidavit, #13 Exhibit 13_Affidavit, #14 Exhibit 14_Affidavit, #15 Exhibit 15_E-Mail, #16 Exhibit 16_Article)(Schiller, Joshua)
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