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United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff,
Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
________________________________/
PLAINTIFF’S AMENDED1 CORRECTED2 REPLY IN SUPPORT OF MOTION TO
EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT
Sigrid McCawley
BOIES, SCHILLER & FLEXNER LLP
401 E. Las Olas Blvd., Suite 1200
1 Pursuant to conferral with opposing counsel, Plaintiff has revised the first paragraph of this brief, as well as the
second-to-last paragraph of Section I of this brief out of a concern Defendant raised with the use of the term “set”
when referring to depositions. In an abundance of caution, to avoid unnecessary disputes and waste of this Court’s
time, the undersigned agreed to revise the brief to remove the language in question. The remainder of this brief is
unchanged.
2 On June 13, 2016, Ms. Giuffre filed her Reply in Support of her Motion to Exceed the Presumptive Ten Deposition
Limit (DE 203). This brief contained excerpt from Rinaldo Rizzo’s “rough” deposition transcript, as the final
transcript had not yet been completed by the stenographer. On June 14, 2016, the stenographer issued the “final”
deposition transcript, and Ms. Giuffre hereby files the final transcript citations and excerpts to replace the “rough”
transcript that accompanied her supporting Declaration (DE 204-2). There are no other changes to this document.
Case 1:15-cv-07433-LAP Document 1320-27 Filed 01/03/24 Page 1 of 15