Case Document Filed Page of Case Document Filed Page of UNITED STATES DISTRICT COURT t.:i SOUTHERN DISTRICT OF NEW YOIU I i VIRGINIA GIUFFRE Plaintiff ERS GHISLAINE MAXWELL Defendant __ AMENDED SECOND PROPOSED DISCOVERY AND CASE MANAGEMENT DEADLINES AND REQUEST TO MODIFY Case Document Filed Page of Case Document Filed Page of The Parties through their respective counsel propose the following case management deadlines and request that the Court enter an order modifying its Order of October ECF for the following reasons Subsequent to the hearing on February the parties have conferred extensively about the viability of the existing case management deadlines The parties agree that the previous deadlines are no longer tenable Accordingly subject to the Courts approval and availability the parties propose the following schedule The jury trial scheduled for March is rescheduled to begin on May and is anticipated to last four weeks Motions in Limine/other motions shall be filed by March Final Exhibit lists shall be exchanged by the parties no later than April and submitted to the Court by April The Revised Joint Pre-trial Order shall be submitted by April Proposed agreed upon/disputed Jury Instructions and Verdict forms shall be submitted by April Proposed jury questions shall be submitted by May The parties suggest that the Court may wish to consider scheduling hearings on outstanding issues as necessary as follows March hearing on Plaintiff Giuffres Motion to Present Testimony from Jeffrey Epstein for Purposes of Obtaining an Adverse Inference ECF hearing on Plaintiffs Motion to Compel all Work Product and Attorney Client Communications with Philip Barden ECF hearing on outstanding motions including Motion to Quash Edwards Subpoena filed in the Southern District of Florida on June under case number and March hearing on Motions ECF and motions in Ii mine April hearing on objections to deposition designations May Pre-trial Conference to address any outstanding issues including confidentiality WHEREFORE the parties request that the Court adopt the proposed schedule and modify the Courts Order of October to reflect the above deadlines Case Document Filed Page of Case Document Filed Page of Dated February Respectfully submitted Isl Bradley Edwards Bradley Edwards FARMER JAFFE WEIS SING EDWARDS FISTOS LEHRMAN P.L North Andrews Ave Ste Ft Lauderdale FL brad pathtojustice.com Attorney for Virginia Giuffre Isl Jeffrey Pagliuca Laura A Menninger Jeffrey Pagliuca pro hac vice Ty Ge pro hac vice HADDON MORGAN AND FOREMAN P.C East th A venue Denver CO Phone Fax jpagliuca hmflaw.com Attorneys for Ghislaine Maxwell Case Document Filed Page of Case Document Filed Page of CERTIFICATE OF SERVICE I certify that on February I electronically served this AMENDED SECOND PROPOSED DISCOVERY AND CASE MANAGEMENT DEADLINES AND REQUEST TO MODIFY
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