Case Document Filed Page EXHIBIT Pursuant to the Courts Individual Practice Rule IA Counsel has removed the Exhibits from the March Letter to the Court Case Document Filed Page ia Fa 267simile lonorablc Judge Robert Sweet United States District Judge Southern District of Jew York Pearl Street Courtroom 8C cw York New York Re Giuffre Maxllell larch I Case No I Sigrid McCawlcy E-mail smccawlcyfitbslp.com We write today in rcsp,mse to Dciendant I 1ax clls March kttcrand to ask the Court to compel the deposition or Ddcnda,n fax well on March The discovery issue before thl Court regarding Defendant vfaxwelrs deposition is straightforward and the Court should order fax well to sit for her deposition On February Plaintiff Giuffre first noticed Dcfondant Max ells deposition for larch Due to Defondant counsels scheduling conlliet Plaintiff Giuffre tried to resol the problem by re-noticing the deposition for March a date for which she understood Maxwell and her counsel were a 267ailahle Despite this Ddcndants counsel refused to produce I la cll fi,r deposition unless ls iiulfrc Ould respond 267ackno lcdging I herj ain ofthl right to take a second dcposi1ion based on the riling o!thc Cr nnd Countcrc!aims To reiterate have not acp!cd hl datL uf 1urch 1lH my clients deposit inn and rill not ugree schedule such de sflion iu the ab la protectfrl order IJU/your a Haiver as outli11et a hove ee xhibit i i ls Ciiuffr is simply trying mo discovery lln 267ard and rcspcctful!y requests tlrnt tile Court direct fv1axwc to sit for her deposition on 1arch The issue is not 267moot as Pdaxwcll represented in her ncr to the Court bccnusc laX is still refusing to sit for hc:r deposition until a Protectivl Order is entered This is nm the first time th,1t Dc cnda11t Max cll has a!l,:mpicd tu avoid a deposition In the civil actions invol ing klfrcy Ep lcin i.:rimi i faxwdl rcprl cntcd she could attend her deposition bcca,1sl she had to leave the 267ountry to car for her ill mother and did not anticip;it,._ returning Thcrc 1fter shi was plwtog1 267aplwd in the United Stat ill a high profile cddi11g Sei Janucl Daily foil article WI illfun pictured i1h Jc:fil rj,1stui11 _1 Socio Fixer at Jd1cil lleddin_s FTU s,it.l"illg With IL"l.d ledophif Case Document Filed Page Lcttcr ll1 I lont r;ibh Judge Rohn1 Swcc1 1arch Page The Court should also tlic lrotecti1e Order that Ms Ciiulfre has recommended In response to vlaxwcll Protective Order demand Pbintiffpro 267idL counsel with a ltd proposed Order based on a fell revisions to the Order that la cll had originally circulated Sec Exhibit 1-cbruary Email Correspondence Those relisions n:asonably pr idcd necessary parameters to prokct from overuse and abuse of the confidential designation Rather than respond to Plaintilrs re 267isions V1a,well filed with the Court a Motion for lrotccti1c Order and submitted her original Prntccti Order to the Court ID J8I Ms Ciiufli is not opposed to the entry ofa Protective Order V1s Giulli-e howe docs ask that 1hc Protective Order include spL 267cilk language concerning the t;pc of information to be protected and the method for challenging Vcrbroad con1idcntial designations to ensure th 1t the Protccti Order is t1ot abused by the llel"cndant Giuffi is setting forth her specific rc1 267isiot1s in her Response to Derendant Ma,11elrs 1utiot1 for Protccti Order 11hich 11ill be l1icd shortly Finally with respect to Ma dls concludit1g remarks tvls Giuffre lirst sent her request for 1a,wcll"s deposition of February To fate 1axwell has still t1ot agreed to sit for her deposition In contrast on Fcbrumy Ci IV1axwc!l"s counsel rcqw.:stcd dates for llaintirts deposition to take place in mid-April laintiffcorrespot1dcd that she was conferring ith her client regarding the proposed dates and would respond i1h a specific date ccnrdingly llaintiffGiulrrc resp,ct!tilly requests that the Court direct ilax ell to sit for her deposition ot1 larch I Cl To tlw ntlt1t the Court is not able tu resolw the Protective Order matter prinr to h1xwc1l"s dcpositil l1 vlarch Plaintiff il agree to treat the entire transcript as confiJcntia until such a time as the Court enters the Pro1cc1i,-c Order A Proposed order tu this effect is a!tachccl See Fxhihit Proposed Order Granting llaintit"!s Vlotion to Crnnpcl ct"cndant lkp,,sition on larch ls Uiulfre also agrees tn sit for her deposition in mid-April alter Ltx,,ells lk1xisi1ion at a dati tkll is mutually conn:nient for the par!its SS,v!/cp nc!t Sll!C Respectfully
