323 results for "January 2 2015"
Page 10 of 13
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...CV 14-2594-GW PLAX, 2015
WL 1057923, at *17 (C.D. Cal. Mar. 9, 2015) (“Plaintiffs may not answer the interrogatory by
generally referring Defendant to the pleadings filed in this case, documents produced, opt-in
questionnaires, depositions, or declarations.... [A] responding party may not answer an
interrogatory by...
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...Attac
hed hereto as Sealed Exhibit 10 is a true and correct copy of January 22,
2015 Dailymail.co article “All aboard The Lolita Express’: Flight Logs.
13. Attac
hed hereto as Sealed Exhibit 11 is a true and correct copy of Excerpts from
June 21, 2016, Deposition of Detective...
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Case 1:15-cv-07433-LAP Document 1320-1 Filed 01/03/24 Page 2 of 2
From: gmax1@ellmax.com
Sent: Saturday, January 10, 2015 9:00 AM
Ta: Philip Barden; Ross Gow
tam out of my depth to understanding defamation and other legal hazards and don’t want...
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...Risks are
exacerbated by the leadership’s lack of experience
in handling financial market volatility, as evidenced
by China’s policy response to its equity market
collapse in June 2015 and its approach to shifting
the currency regime to a more flexible one in
August 2015 and January 2016. We...
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...On January 1, 2015, Ms. Giuffre filed a “corrected” joinder motion. Ex.D at 1, 9.
a. Reply: Plaintiff “agreed” to this paragraph.
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CHAPTER 64
Declaration of Virginia Roberts Giuffre, filed on
January 19, 2015 by attorneys representing Jeffrey
Epstein’s victims (continued)
20. Harvard law professor Alan Dershowitz was around
Epstein frequently. Dershowitz was so comfortable with the
sex [that] was going on that on one occasion he observed me
in sexual...
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...The video(s) of Ghislaine Maxwell adopting the January, 2015 press statement.
4. All newspaper or other media where Ghislaine Maxwell’s press release appears
5. All evidence obtained by the Federal Bureau of Investigations which relate in any way
to Jeffrey Epstein or Ghislaine Maxwell.
6. All 302 statements...
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CHAPTER 64
Declaration of Virginia Roberts Giuffre, filed on
January 19, 2015 by attorneys representing Jeffrey
Epstein’s victims (continued)
20. Harvard law professor Alan Dershowitz was around
Epstein frequently. Dershowitz was so comfortable with the
sex [that] was going on that on one occasion he observed me
in sexual...
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...Jason Karaian, “Putin Has Friends on Europe's Far Right and Left (but Mostly Right),” Quartz, January 15, 2015, http://
gqz.com/326487/putin-has-friends-on-europes-far-right-and-left-but-mostly-right/.
11. Amber Phillips, “Paul Manafort’s Complicated Ties to Ukraine, Explained,” Washington Post, August 19...
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...Giuffre’s declarations as “untrue” and “lies” from when the statements were made on 2
January 2015 to the date that I filed this report?
9. For brevity, I refer to references to the statements denoting Ms. Giuffre’s
declarations as “untrue” and “lies”, any related accounts referring to those...
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...Tuesday, January 20, 2015 12:14 AM
To:
Subject: your statement?
Importance: High
I have to hand it 1 ii I'm sure she deserves the pretty penny she has made for her effort . She has
certainly caught the imagination of a public hungry for salacious fiction. To suggest her...
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...that was end of january Training brad?? who was your choice . not mine ,by a long shot. only
brought on in january? ? hundreds of hours spent . eileen debrief? 2. boat. plane
household ex[penses. personal review? , trying to create accurate ledgers of capital expenses . so to minimize
future gain.? 3...
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...Gow to issue the January 2015 statement. Mot. 3. We suggest plaintiff's persistent repetition
of her arguments—as with any repetition, they have become familiar, but not more persuasive—
suggests her recognition that we have advanced meritorious and weighty arguments for summary
‘Mot. 3 (emphasis supplied).
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...e sworn testimony from one of Epstein’s household employees (Juan Alessi) that
Dershowitz came “pretty often” to Epstein’s Florida mansion and got massages
while he was there;
> The Joinder Motion attached as an exhibit is a “corrected” motion, filed on January 2, 2015. As discussed below,
several paragraphs...
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...Application of these factors to the January 2015 statement compels the conclusion that
the allegedly defamatory words, phrases and clauses are nonactionable opinion.
Whether the specific language in issue has a precise meaning which is readily
understood or whether it is indefinite and ambiguous. The three sentences plaintiff alleges are...
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...at Exhibit 2, January 8, 2015, The Sun (online) article: “Prince
99
Andrew’s pal Ghislaine ‘groped teen girls,”” (Miss Maxwell’s spokesman branded the
accusations against her a “web of lies and deceit” — adding: “None of these allegations are on
oath. “These girls are saying anything they want for...
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Case 1:15-cv-07433-LAP Document 1330-21 Filed 01/05/24 Page 2 of 11
From: gmax1@ellmax.com
Sent: Saturday, January 10, 2015 9:00 AM
To: Philip Barden; Ross Gow
!am out of my depth to understanding defamation and other legal hazards and don't want...
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...Maxwell has learned of at least five other medical treatment
providers in the most relevant timeframe — people providing medical and mental health services
post the alleged defamatory statement in January 2015. Plaintiffs discovery failures in hiding
relevant treating physician information have prevented Ms. Maxwell from obtaining what now
appears to...
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...Whether the three sentences in the January 2015 statement are capable of being
objectively characterized as true or false. Can the three sentences be characterized as true or
false? They cannot, because the statement does not specify which of the many dozens of
allegations plaintiff has made are “untrue” and...
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...Barden discusses his intent and purpose
in preparing the January 2015 statement. We quote in full the two sentences so that the Court can
see for itself the remarkably frivolous nature of the argument: “I did not ask Ms. Maxwell to
respond point by point to Ms. Giuffre’s factual...
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...Gow presented the January 2015 statement
via email to six to thirty media representatives; it was not sent to anyone else; in the email he
told the journalists he was presenting a “quotable statement” “‘on behalf of’ Ms. Maxwell and
“Tnjo further communication will be provided.” Doc.542-6, Ex...
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...Friday, January 16, 2015 9:37 AM
To: Mortimer Zuckerman
Subject: thoughts?
Out of respect and love for my former girlfrend I have tried to keep her out of my mess. she was never
questioned , or subpeonaed. her name never surfaced. Marie never contacted her. I though it right as...
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...Exhibit 2?
A. [really can't remember but certainly more than six and probably less than 30,
somewhere in between. Any time there was an incoming query it was either dealt with on
the telephone by referring them back to the two statements of March 2011 and January
2015 or...
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Zee
CHAPTER TWO
The Crime Scene Investigation
1. “Any private contractor...”—Snowden Interviewed by Brian Williams, NBC,
May 28, 2014 (Hereinafter Snowden NBC Interview.)
2. “About 15 miles....°-—U.S. Navy Information Operations Command, “History
of NIOC Hawaii”, http://www.public.navy.mil/fec-
c10f/niochi/Pages/AboutUs.aspx
3...
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...linked.
$/Ounce %
2,000 15
1,600
1,200
800
vi i ow 2.0
* (
400 % wv y) " Gold Price 25
d 2 —— == 10-Year US Real Rate (Right, Inverted) 3.0
t 4
0 3.5
2006 2007 2008 2009 2010 2011 2012 2013 2014 2015 2016
Data through...
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