1320-33.pdf

"VIRGINIA L. GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant."

"GHISLAINE MAXWELL, Defendant. 15-cv-07433-RWS"

"Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion... Laura A. Menninger"

"Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Motion... Jeffrey S. Pagliuca"

"Laura A. Menninger HADDON, MORGAN, AND FOREMAN, P.C."

"Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C."

"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK... 15-cv-07433-RWS"

"On February 12, 2016, Ms. Maxwell served Interrogatories on Plaintiff... (Interrogatory No. 12)"

"Case 1:15-cv-07433-LAP ... preclusion of Plaintiff’s claims regarding physical and emotional distress damages is the appropriate sanction"

"Ms. Maxwell has learned of at least five other medical treatment providers in the most relevant timeframe – people providing medical and mental health"

"Attorneys for Ghislaine Maxwell"

"Attorneys for Ghislaine Maxwell"

"Laura A. Menninger (LM-1374) Jeffrey S. Pagliuca (pro hac vice) HADDON, MORGAN AND FOREMAN, P.C."

"Dr. Heaney, Donna Oliver P.A and Dr. Streeter – reside in Colorado."

"Sigrid S. McCawley BOIES, SCHILLER & FLEXNER, LLP"

"Plaintiff’s discovery abuses have been rampant since the beginning of this case. In the case of withholding required documents and information regardi"

"Allyson Chambers – subpoena February 12; disclosed March 11"

"Joe Recarey – subpoena notice May 17; disclosed June 1"

"Michael Reiter – subpoena notice May 17; disclosed June 1"

"relevant to, and necessary to defend against, Plaintiff’s damages claims for psychological and psychiatric injuries and resulting medical expenses"

"seeking the names of treatment providers subsequent to the Alleged Defamation... Plaintiff sent Ms. Maxwell additional records"

"Case 1:15-cv-07433-LAP Document 1320-33... Plaintiff failed therein to identify any treatment providers prior to the alleged defamation"

"Case 1:15-cv-07433-LAP Document 1320-33... Ms. Maxwell first sought the identities of Plaintiff’s health care providers"

"deposition of Plaintiff’s mother, Lynn Miller, on May 24, 2016"

"Ms. Maxwell has been severely prejudiced by Plaintiff’s failure to provide the required identifying information and documents from her health care pro"

"One health care provider identified by Plaintiff in her deposition is a psychiatrist, Judith Lightfoot, who is located in Australia. ... document from"

"At her deposition, Plaintiff intentionally concealed other treating physicians who treated her"

"Plaintiff was specifically asked for photographs of Plaintiff with certain individuals (including Prince Andrew)"

"she was treated at a hospital for a domestic violence incident in which her husband strangled and punched her"

"Plaintiff turned over additional relevant documents from Plaintiff’s iCloud account, but only did so after Ms. Maxwell’s counsel ferreted out that acc"

"Aviation Insurance – subpoena April 27; never disclosed"

"Plaintiff produced additional documentation from Centura Health for treatment received by Plaintiff in March 2015"

"Menninger Decl., Ex. E. ... undersigned counsel sent a confirming letter to Plaintiff’s counsel setting forth the precise information required"

"Menninger Decl., Ex. E at 26-27... Menninger Decl., Ex. G"

"During the deposition of Plaintiff’s mother, Lynn Miller, on May 24, 2016, Ms. Maxwell learned that"