Search results for 01/05/24
1,750 results for "01/05/24"
Page 58 of 70
Giuffre_Maxwell_Batch4_p00368.png
Case 1:15-cv-07433-LAP Document 1328-20 Filed 01/05/24 Page 11 of 14
Plaintiff has not cited any authority for the redaction of information from the Colorado police
reports.
IL. PLAINTIFF HAS WAIVED ANY ARGUMENT AS TO CONFIDENTIALITY
A. Plaintiff Failed to Timely Move this Court...
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Court Filing
Case 1:15-cv-07433-LAP Document 1330-3 Filed 01/05/24 Page 22 of 26
21. Victims Refuse Silence 2016 Annual Report, attached hereto as Exhibit 21.
22. January 3, 2015 Daily Mail article: “Harvard Law Professor Named Alongside
Prince Andrew in ‘Sex Slave’ Case Accuses Alleged Victim...
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Deposition
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 4 of 12
Q. Sorry. I'm talking about when you worked there and you would receive a message that
they were coming into town, would that be by way of telephone?
A. Telephone, and also...
Giuffre_Maxwell_Batch6_p00104.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 15 of 21
Plaintiffs counsel provided with a copy of a statement she gave to the police in
October 2005 concerning Mr. Epstein. refused to look at the statement and did not
authenticate it in any...
Giuffre_Maxwell_Batch6_p00369.png
Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 9 of 11
DOCUMENTS TO BE PRODUCED
1. All Documents containing Communications with Virginia Roberts Giuffre, or any of her
attorneys, agents, investigators, from the period 1999-present.
2. All fee agreements for Your engagements with...
Giuffre_Maxwell_Batch3_p00064.png
Deposition
Case 1:15-cv-07433-LAP Document 1327-5 Filed 01/05/24 Page 4 of 17
points throughout her deposition, Defendant refused to answer questions about subjects integral
to this lawsuit, including questions about a student, Joanna Sjoberg, who Defendant recruited
from her school to give massages to, and...
Giuffre_Maxwell_Batch4_p00535.png
Legal
Case 1:15-cv-07433-LAP Document 1328-31 Filed 01/05/24 Page 10 of 13
Defendant fails to mention that a forensic review would not give Ms. Giuffre - or the Court, or
anyone in the world - access to, or knowledge of “highly sensitive information” that is not
directly...
Giuffre_Maxwell_Batch4_p00609.png
Legal
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 17 of 31
presumption’s reach...” Amodeo II, 71 F.3d at 1050. Dershowitz suggests that because a
subpoenaed third party filed one of the documents as an attachment to a motion to quash, and
because...
Giuffre_Maxwell_Batch4_p00619.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 27 of 31
confidentiality of report of policing failures surrounding the murder of a young mother).
“Consequently, in a major decision in this field, Martindell v. International Telephone &
Telegraph Corp., 594 F.2d 291 (2d Cir...
Giuffre_Maxwell_Batch5_p00168.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-11 Filed 01/05/24 Page 9 of 12
“An adverse inference serves the remedial purpose of restoring the prejudiced party to the
same position he would have been in absent the wrongful destruction of [or willful refusal to
produce] evidence by...
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Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 6 of 17
c. The EarthLink account
The second account, SN, is, as Ms. Maxwell has repeatedly explained
to Plaintiff's counsel, an account that she does not recognize, that she does not recall having ever...
Giuffre_Maxwell_Batch6_p00379.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 8 of 10
Opposition to Motion to Present Epstein Testimony at 15. Moreover, presenting Mr. Epstein’s
deposition testimony in which he asserted his Fifth Amendment privilege in response to questioning
regarding plaintiff's allegations would...
Giuffre_Maxwell_Batch4_p00158.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 29 of 32
and not the Court, to set the standards for access. “A blanket protective order is more likely to
be subject to modification than a more specific, targeted order because it is more difficult...
Giuffre_Maxwell_Batch4_p00145.png
Legal
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 16 of 32
Id. § 43.
even though she had accused other prominent people of abusing her and
had plenty of opportunity to do so.
In an exchange of emails in 2011, Ms. Churcher, who was advising...
Giuffre_Maxwell_Batch5_p00326.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-23 Filed 01/05/24 Page 6 of 9
defendants' delay in producing documents may have interfered with the completeness of
depositions, plaintiff will be free to reopen any depositions for which he deems the newly
produced documents to be a relevant...
Giuffre_Maxwell_Batch6_p00068.png
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 12 of 21
claim you finished being sexually trafficked, correct?” A. “Yes.” Jd. at 206:16-22). Even if Ms.
Giuffre contemplated any litigation having anything to do whatsoever with what was in that
journal, she...
Giuffre_Maxwell_Batch4_p00613.png
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 21 of 31
would not be making any decision on the merits, but I would simply be reviewing excerpts of the
transcripts to resolve a discovery dispute.”).
This ruling is in-line with the Second Circuit...
Giuffre_Maxwell_Batch6_p00065.png
Legal
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 9 of 21
The key fact is that Defendant fails to offer any explanation whatsoever for her delay in
bringing this motion. Therefore, this Court should reject Defendant’s motion as untimely. See
Gutman v. Klein...
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Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 24 of 50
Wheatley, 165 Misc.2d 954, 958, 630 N.Y.S.2d 835, 838 (N.Y. Sup.Ct. 1995) (holding that in a
personal injury action, plaintiff’s waiver of the physician-patient privilege...
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Case 1:15-cv-07433-LAP Document 1330-4 Filed 01/05/24 Page 17 of 27
The following statement made by Virginia Roberts’s attorneys in a
filing on January 21, 2015 is not accurate and is a
misrepresentation of what I said in my deposition: “the private,
upstairs...
Giuffre_Maxwell_Batch5_p00234.png
Court Filing
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 4 of 17
searched all accounts that she can access. Had Plaintiff bothered to follow up on this alleged
communication, Ms. Maxwell would have reaffirmed that there is no “undisclosed” email
account. Instead, Plaintiff filed this...
Giuffre_Maxwell_Batch3_p00309.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 3 of 27
Defendant Ghislaine Maxwell, by and through her counsel, hereby submits the following
Response in Opposition (“Response”) to Plaintiff's Motion to Enforce the Court’s Order and
Direct Defendant to Answer Deposition Questions...
Giuffre_Maxwell_Batch4_p00423.png
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 11 of 22
discovery [of financial information] avoids the inefficiency of a discovery delay between the
liability and damages phases of trial, as well as the need to assemble a second jury.”’).
Finally, Defendant relies upon...
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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 17 of 21
The Second Circuit has stated, “[w]here documents, witnesses, or information of any
kind relevant issues in litigation is or was within the exclusive or primary control of a party and
is not...
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Legal
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 4 of 22
including Jeffrey Epstein, Nadia Marcikova, and Sarah Kellen — depositions that have thus far
been defeated by evasions of service of process and other similar maneuvers. See DE 160,
Motion for Leave to Serve...
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