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efta-efta00625094DOJ Data Set 9Other

09/13/2016 18:1k FAX

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DOJ Data Set 9
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efta-efta00625094
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EFTA Disclosure
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09/13/2016 18:1k FAX ease 1:15-cv-07433-RWS Document 433 Filed 09/15/16 Page 1 of I Q0002/0003 PO ES SCH LLER R FLEXNER LLR 401 EAST LAS OLAS BOULEVARD • I200 • LAuDFRDALE September 13, 2016 VIA FASCIMILE 1212-805-79251 Honorable Judge Robert W. Sweet District Court Judge United States District Court 500 Pearl Street New York, NY 10007 Re: Giuffre v. Maxwell, Case No.: 15-cv-07433-RWS Dear Judge Sweet: -22il • PH. 954.356 00il • rA Si id S. McCawley. Esq. E-mail: 2 ,TECEOWIE - Th ISEP 1 12016 I JUDGE SWEET CHAMBERS USDC SDNY ELECTR a A 7 t Y Fl! DOC //: DATE FILED: Plaintiff, provides this Court with Notice of Non-Response to the Court's July 30, 2016 Order. S cificall on June 20, 2016, this Court authorized the sub to and to be served by alternative means. served subpoenas as directed by the Court and set the depositions of and for July 21, 2016 at the Boies Schiller & Flexner offices in New York City. Neither of the witnesses appeared for their depositions. On Jul 25 2016, filed Plaintiffs Motion for a Finding of Civil Contempt For Ignoring Subpoena and For Associated Sanctions (308) and Plaintiffs Against Motion for a Finding of Civil Contempt Against For Ignoring Subpoena and For Associated Sanctions 310). In her motions, Plaintiff sou t the folio ' relief in order to compel the depositions of and and be directed to appear for deposition ( ) that and pay costs and reasonable attorney's fees associated with bringing the motion, and that (3) and be ordered to pay a civil penalty of S2500 per day for each day after which they fail to appear at the rescheduled deposition and any other sanction the court believes is just and proper. On July 30, 2016 the Court issued the folio order: "ORDER: Plaintiffs Motions for a Finding of Civil Contempt against and shall be taken on submission returnable August 25, 2016. All papers shall be served in accordance with Local Civil Rule 6.1 and pursuant to this Courts previous orders. (Signed by Judge Robert W. Sweet on 7/30/2016) (cf)". WWW.BSFLLP COM EFTA00625094 09/13/2018 18:LA FAX ease 1:15-cv-07433-RWS Document 433 Filed 09/15/16 Page I of I a] 0003/0003 Boles. SCHILLER & FLEXNER LLP Honorable Judge Sweet District Court Judge September 13, 2016 Page 2 Neither on or before August 25, 2016. In light of these facts, a Finding of Civil Content • t indicated in that motion and and pa bringing the motion, and that (3) penalty of S per day for each deposition any other sanction SSM Enclosure cc: Counsel of Record nor filed any response to the Plaintiffs Motion rovides notice to this Court that Plaintiffs Motion for and remain pending. As would respectfully request that the Court Order that (1) that be directed to appear for deposition (I) that costs and reasonable attorney's fees associated with and be ordered to pay a civil day after which they fail to appear at the rescheduled the court believes is just and proper. Sincerely, So rz eter/ i5coLe_crasaci- f- EFTA00625095

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Case #1:15-CV-07433-RWS

Related Documents (6)

DOJ Data Set 9OtherUnknown

UNITED STATES DISTRICT COURT

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK x UNITED STATES OF AMERICA S 120 Cr. 330 (AJN) GHISLAINE MAXWELL, Defendant. x THE GOVERNMENT'S OMNIBUS MEMORANDUM IN OPPOSITION TO THE DEFENDANT'S PRE-TRIAL MOTIONS AUDREY STRAUSS United States Attorney Southern District of New York Attorney for the United States of America Assistant United States Attorneys - Of Counsel - EFTA00039421 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 BACKGROUND 2 ARGUMENT 3 I. Jeffrey Epstein's Non-Prosecution Agreement Is Irrelevant to This Case 3 A. The NPA Does Not Bind the Southern District of New York 4 1. The Text of the Agreement Does Not Contain a Promise to Bind Other Districts 5 2. The Defendant Has Offered No Evidence That the NPA Binds Other Districts 9 B. The NPA Does Not Immunize Maxwell from Prosecution 15 1. The NPA Is Limited to Particular Crimes Between 2001 and 2007 15 2. The NPA Does Not Confer Enforceable Rights on Maxwell 17 C. The Defendant

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Case 1:15-cv-07433-RWS Document 914 Filed 05/11/17 Page 1 of 1

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18-2868; 16-3945-cv(L)

18-2868; 16-3945-cv(L) Brown v. Maxwell; Dershotvitz v. Giuffre 3n tlje Elute)) i§tateo Court of appeat55 for the i§ecortb Circuit AUGUST TERM 2018 No. 18-2868-cv JULIE BROWN, MIAMI HERALD COMPANY, Intervenors-Appellants, v. GHISLAINE MAXWELL, Defendant-Appellee, v. VIRGINIA L. GIUFFRE, Plaintiff-Appellee. No. 16-3945-cv(L) No. 17-1625 (CON) No. 17-1722(CON) ALAN M. DERSHOWITZ, MICHAEL CERNOVICH, DBA CERNOVICH MEDIA, Intervenors-Appellants, EFTA00092308 V. VIRGINIA L. GIUFFRE, Plaintiff-Appellee, v. GHISLAINE MAXWELL, Defendant-Appellee: On Appeal from the United States District Court for the Southern District of New York ARGUED: MARCH 6, 2019 DECIDED: JULY 3, 2019 Before: r —ABRANES, POOLER, and DRONEY, Circuit Judges. Intervenors-Appellants Alan Dershowitz, Michael Cernovich, and the Miami Herald Company (with reporter Julie Brown) appeal from certain orders of the United States District Court for the Southern District of New York (Robert W. Sweet,

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