Search results for 01/05/24
1,750 results for "01/05/24"
Page 55 of 70
Giuffre_Maxwell_Batch6_p00108.png
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 19 of 21
Like J Mr. Rodriguez was expansively questioned based on counsel’s recitation
of the alleged content of a recorded statement from Mr. Rodriguez to Detective Recarey and then
he was asked questions regarding...
Giuffre_Maxwell_Batch6_p00168.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-13 Filed 01/05/24 Page 10 of 22
concern is fundamentally whether the adverse inference is trustworthy under all of the
circumstances and will advance the search for the truth.” Id. at 124 (emphasis added). A number
of subsequent decisions from...
Giuffre_Maxwell_Batch6_p00239.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-19 Filed 01/05/24 Page 7 of 12
yet has failed to produce any of the related documents. Accordingly, Ms. Giuffre respectfully
requests that this Court direct the Defendant to produce all work product documents, including
but not limited to all...
Giuffre_Maxwell_Batch6_p00377.png
Legal
Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 6 of 10
his video deposition is the functional equivalent of an in-person assertion, the distance of travel
required and the expenses which would be incurred—here, not just the cost of travel to New...
Giuffre_Maxwell_Batch5_p00165.png
Deposition
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 6 of 12
Q. That's not something that you were, you were privy to? You weren't, you weren't in the
loop of the sharing of information in the house in terms of the...
Giuffre_Maxwell_Batch5_p00205.png
Legal
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 18 of 43
an order requiring disclosure. Fed. R. Civ, P. 37(a)(1). The motion must also be made in the
Court where the discovery is to be taken —i.e., in this Court. Fed...
Giuffre_Maxwell_Batch5_p00243.png
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 13 of 17
culpable state of mind, nor is any argued. How can one have a culpable state of mind where
there are no additional accounts to search or documents to be produced?
Finally, and perhaps...
Giuffre_Maxwell_Batch4_p00157.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 28 of 32
I. ALTERNATIVELY, THE PROTECTIVE ORDER SHOULD BE MODIFIED TO
PERMIT DISCLOSURE OF THE REQUESTED DOCUMENTS
Even where discovery materials are found not to be judicial documents, that does not
automatically entitle them to...
Giuffre_Maxwell_Batch4_p00164.png
Flight Log
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 3 of 12
proceedings (apparently, also forgetting the 23 flights she shared with Ms. Giuffre on Epstein’s
private jet,° known colloquially as the “Lolita Express”).
Police Detective Joseph Recarey, who led the investigation of Epstein...
Giuffre_Maxwell_Batch4_p00165.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-7 Filed 01/05/24 Page 4 of 12
Both Sarah Kellen and Nadia Marcinkova invoked the Fifth Amendment when asked about
Defendant trafficking girls’ in a previous action, and both failed to show up for their depositions
in this case.
Also...
Giuffre_Maxwell_Batch4_p00339.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 36 of 50
(emphasis added), quoting 7: Rowe Price Small-Cap Fund, Inc. v. Oppenheimer & Co., Inc., 174
F.R.D. 38, 43 (S.D.N.Y. 1997). Admitting or denying this statement does not eliminate...
Giuffre_Maxwell_Batch5_p00323.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 3 of 9
attempted to solicit Defendant’s testimony pursuant to the Court’s Order, but Defendant defied that
Order and again refused to answer many questions, thus requiring Ms. Giuffre to file the Motion to...
Giuffre_Maxwell_Batch5_p00324.png
Legal
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 4 of 9
communications in January of 2015, whereas this newly- produced communication shows discussions
with Gow from November of 2015 - after this litigation had commenced. Therefore, Ms. Giuffre is
entitled to ask the Defendant about...
Giuffre_Maxwell_Batch6_p00262.png
Case 1:15-cv-07433-LAP Document 1331-22 Filed 01/05/24 Page 6 of 9
press to stop and think before publishing, to cease and desist, and that if they continued then they
faced higher damages for ignoring my clear warning.
19. Consistent with those two purposes, Mr...
Giuffre_Maxwell_Batch3_p00314.png
Deposition
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 8 of 27
The continued deposition was expressly limited to the above eight categories, and the
Court instructed that Ms. Maxwell “need not answer questions that relate to none of these
subjects or that is clearly...
Giuffre_Maxwell_Batch4_p00285.png
Deposition
Case 1:15-cv-07433-LAP Document 1328-15 Filed 01/05/24 Page 2 of 6
Page 3}:
IN THE CIRCUIT COURT OF THE ISTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502008CA028051XXXXMB AB
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO. 08...
Giuffre_Maxwell_Batch4_p00414.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 2 of 22
financial information from just the time during which Defendant has defamed Ms. Giuffre (2015
to present).
As with most of the other discovery requests she has received, Defendant has chosen not
to produce...
Giuffre_Maxwell_Batch6_p00097.png
Legal
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 8 of 21
Because of his invocation of his Fifth Amendment right to remain silent, there actually is
no deposition testimony to designate. Each designation reflects a leading question by Plaintiffs
counsel (which is improper on...
Giuffre_Maxwell_Batch6_p00105.png
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 16 of 21
Cc. Phillip Esplin
As previously explained, Dr. Esplin is a retained rebuttal expert, responding to the
improper credibility opinions of Dr. Kliman and Professor Coonan. His opinions are quite
limited in scope, and...
Giuffre_Maxwell_Batch6_p00261.png
Case 1:15-cv-07433-LAP Document 1331-22 Filed 01/05/24 Page 5 of 9
she is, since both statements cannot as a matter of fact be true. When someone says she did not
have sex and then says she did, in other words, there is an obvious...
Giuffre_Maxwell_Batch3_p00065.png
Deposition
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 5 of 17
might become known to Epstein.” Ms. Sjoberg is an important witness in this case — one of the
witnesses Ms. Giuffre has deposed. She is an individual Defendant knew to be known to
Epstein...
Giuffre_Maxwell_Batch4_p00072.png
Case 1:15-cv-07433-LAP Document 1328-4 Filed 01/05/24 Page 28 of 40
(emphasis supplied). Plaintiff denied only “a part of a matter” and therefore was required to
“specify the part admitted.” In Request for Admissions Nos. 1-8 and 13, Plaintiff failed to
specify any...
Giuffre_Maxwell_Batch4_p00103.png
Case 1:15-cv-07433-LAP Document 1328-5 Filed 01/05/24 Page 19 of 45
This document is CONFIDENTIAL under the Court’s Protective Order (DE 62)
rape” in reference to police reports describing incidents that took place when Ms. Giuffre was
fourteen years old. (March 21, 2016...
Giuffre_Maxwell_Batch4_p00275.png
Case 1:15-cv-07433-LAP Document 1328-13 Filed 01/05/24 Page 8 of 9
Louella Rabuyo - Volume I
81
A When | came back to report, that's how |
learned.
Q_ Elaborate on that for me. What do you mean,
when you came back to report that's...
Giuffre_Maxwell_Batch4_p00408.png
Court Filing
OQS - ViG#ER Che NohE39d94P gPocument 1328-22 Filed 01/05/24 Page 18 @gé 16 of 20
PALM BEACH COUNTY SHERIFF'S OFFICE PAGE 5
CASE NO. 98041883 SUPPLEMENT 6 OFFENSE REPORT CASE NO. 98041883
DISPOSITION: OPEN
REMEMBER SMOKING A BOWL, A PIPE". JI ASKED JOSH IF THE BOWL...
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