Case 1:15-cv-07433-LAP Document 1219-1 Filed 07/15/21 Page 1 of 18 United States District Court Southern District of New York Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. PLAINTIFF'S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTION AND IMPROPER CLAIM OF PRIVILEGE Plaintiff by and through her undersigned counsel, respectfully submits this Motion to Compel Production of Documents in response to request nos. 1, 2, 3, 6, 7, 9, 10, 11, 12, 17, and 18, and Motion to Compel Production of certain documents on Defendant's Third Amended Privilege Log. For the reasons set forth below, this Court should grant Plaintiff's Motion in its entirety. I. FACTUAL BACKGROUND1 'On Wednesday, June 8, 2016, the undersigned sent Defendant's counsel a lengthy and detailed letter concerning the deficiencies in Defendant's production in response to Plaintiff's Second Request for Production. See Decl. at Exhibit 1. In that letter, the undersigned proposed we meet and confer call at Defendant's counsel's convenience over the next couple days. On Monday, June 13, 2016, the following business day, the undersigned wrote again r uesting a meet and confer call, again offering the next couple days to have the call. See Decl. at Exhibit 2. Again, the undersigned received no response whatsoever. Tellin 1 . it was not until July 16, 2016, when Defendant wanted to meet and confer about discovery that Defendant finally agreed to discuss these issues. The meet and confer call took place on July 26, 2016, and lasted two hours. See McCawley Decl. at Composite Exhibit 3, July 18, 2016, Email from Paul Cassell to Ty Gee, and July 21, 2016; Email from Paul Cassell to Ty Gee. EFTA02786980