Search results for 01/05/24
1,750 results for "01/05/24"
Page 49 of 70
Giuffre_Maxwell_Batch6_p00013.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 5 of 48
broad under Rule 26(b)(1), Fed. R. Civ. P. Specifically, Ms. Giuffre objects to the requests as
overly burdensome to the extent that they would require logging voluminous and ever-increasing
privileged...
Giuffre_Maxwell_Batch6_p00328.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 12 of 27
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this request in that the
face of the request...
Giuffre_Maxwell_Batch3_p00313.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 7 of 27
Epstein’s assistants would arrange times for underage girls to perform sexual massages.
Pagliuca Decl., Ex. C at 253-55. She was extensively questioned about various message pads
recovered from Jeffrey Epstein’s...
Giuffre_Maxwell_Batch4_p00428.png
Deposition
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 16 of 22
Defendant and Gow had been coordinating the attacks on Ms. Giuffre. In November 10, 2015,
after this defamation suit was filed, Defendant continued to use Gow as her press agent, as
demonstrated in...
Giuffre_Maxwell_Batch4_p00529.png
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 4 of 13
make that showing. “Such showings must be based on competent evidence, usually through
affidavits, deposition testimony, or other admissible evidence.” Egiazaryan v. Zalmayev, 290
F.R.D. 421, 428 (S.D.N.Y...
Giuffre_Maxwell_Batch5_p00210.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 23 of 43
the only possible claim Epstein can raise is not that the document he possesses are in some sense
incriminating, but only that the act of producing those documents is incriminating. See United
States...
Giuffre_Maxwell_Batch6_p00012.png
Case 1:15-cv-07433-LAP Document 1331-3 Filed 01/05/24 Page 4 of 48
in violation of Rule 33. We ask that you immediately withdraw those interrogatories that exceed
the 25 interrogatory limit set by Rule 33.
Ms. Giuffre objects to Defendant’s First Set of Discovery...
Giuffre_Maxwell_Batch6_p00174.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 16 of 22
Defendant obviously cannot dispute that the requirements of item (A) are met, since Mr.
Rodriguez’s former testimony was given in a deposition.
The only remaining issue for admissibility concerns item (B), which...
Giuffre_Maxwell_Batch3_p00200.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 7 of 11
in anticipation of a potential lawsuit in the United Kingdom. See Menninger Decl. at paragraph
8. The documents concerning Mr. Barden have been added to the privilege log. Id.
Upon receipt of Plaintiff...
Giuffre_Maxwell_Batch4_p00415.png
Legal
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 3 of 22
Defendant, “the daughter of the late disgraced press baron Robert Maxwell, has sold her
townhouse at 116 E. 65" St. for $15 million.” See http://nypost.com/2016/04/28/alleged-epstein-
madam...
Giuffre_Maxwell_Batch4_p00466.png
Case 1:15-cv-07433-LAP Document 1328-28 Filed 01/05/24 Page 9 of 24
12. Any copy of a Document that is not identical shall be considered a separate
document.
13. If any requested Document cannot be produced in full, produce the Document to
the extent possible...
Giuffre_Maxwell_Batch5_p00192.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 5 of 43
improper Fifth Amendment objections because there is no risk of incrimination because these
proceedings will be under seal.
Moreover, under the Protective Order issued by the New York case, Ms. Giuffre’s
counsel...
Giuffre_Maxwell_Batch6_p00169.png
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 11 of 22
question being asked and independent corroboration for the adverse inference being drawn. The
jury can also be instructed that it should draw such an inference only where, in light of all the
other...
Giuffre_Maxwell_Batch6_p00219.png
Case 1:15-cv-07433-LAP Document 1331-16 Filed 01/05/24 Page 8 of 10
(3) it is more probative on the point for which it is offered than any other evidence that
the proponent can obtain through reasonable efforts; and
(4) admitting it will best serve the...
Giuffre_Maxwell_Batch4_p00058.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 14 of 40
defamed by Alan Dershowitz, but she failed to provide any information about the allegedly
defamatory statements made by Mr. Dershowitz. For example, she failed to disclose “[t]he exact
false statement[s]” made...
Giuffre_Maxwell_Batch4_p00062.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 18 of 40
before the court in April concerned discovery of Plaintiff's medical records because those
records bore on her claim she had suffered “sex trafficking” damages. Interrogatory No. 13 does
not seek medical information...
Giuffre_Maxwell_Batch4_p00170.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 9 of 12
involving Epstein;” (2) “questions relating to [Defendant’s] knowledge of sexual activities of
others ... with or involving underage females known to Epstein or who Defendant believed
were known or might become known to...
Giuffre_Maxwell_Batch4_p00364.png
Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 7 of 14
copying and redaction fees. As such, there is no “privacy” interest in preserving these
documents obtained in such fashion as “Confidential” under the Protective Order.
Indeed, in February 2015, the New York Daily...
Giuffre_Maxwell_Batch4_p00418.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 6 of 22
punishment or deterrence resulting from a judgment is to some extent in proportion to the means
of the guilty person.” Restatement (Second) of Torts § 908, cmt. e (1979).
Defendant does not attempt to...
Giuffre_Maxwell_Batch5_p00005.png
Case 1:15-cv-07433-LAP Document 1330-1 Filed 01/05/24 Page 4 of 13
reason: “Our position is that we oppose adding new petitioners at this stage of the litigation.” See
DE 291 at 5.
10. Because the Government now contested the joinder motion, Edwards and I...
Giuffre_Maxwell_Batch5_p00074.png
FBI Report
...Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 20 of 26
3. 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...
Giuffre_Maxwell_Batch5_p00256.png
Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 9 of 12
Q. Then why you were communicating with him about statements you were
making to the press?
A. Insofar as this is the case, it's really all about Jeffrey, it's not a...
Giuffre_Maxwell_Batch6_p00107.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 18 of 21
Mr. Bradley Edwards, counsel in this case. According to the Criminal Complaint filed against
Mr. Rodriguez in 2009, Mr. Rodriguez approached one of the lawyers and offered to sell the
lawyer evidence against...
Giuffre_Maxwell_Batch6_p00213.png
Legal
Case 1:15-cv-07433-LAP Document 1331-16 Filed 01/05/24 Page 2 of 10
Defendant Ghislaine Maxwell (“Ms. Maxwell”) files her Reply in Support of the Motion
in Limine to Exclude In Toto certain depositions designated by Plaintiff for use at trial and states
as follows:
I...
Giuffre_Maxwell_Batch6_p00336.png
Legal
Case 1:15-cv-07433-LAP Document 1331-31 Filed 01/05/24 Page 20 of 27
allegedly relevant to another Federal Action styled JANE DOE 43 v. Jeffrey Epstein, Ghislaine
Maxwell, Sarah Kellen, Lesley Groff, and Natalya Malyshev Case Number 1:17-cv-00616-JGK
(S.D.N.Y...
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