Search results for 01/05/24
1,750 results for "01/05/24"
Page 59 of 70
Giuffre_Maxwell_Batch6_p00217.png
Case 1:15-cv-07433-LAP Document 1331-16 Filed 01/05/24 Page 6 of 10
All testimony from J deposition based on leading questions summarizing her
hearsay statements in the police report must be excluded.
With respect to the police report itself, this will obviously be a subject...
Giuffre_Maxwell_Batch6_p00345.png
Flight Log
Case 1:15-cv-07433-LAP Document 1331-32 Filed 01/05/24 Page 2 of 4
CONFIDENTIAL
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v.
Ghislaine Maxwell,
Defendant.
AFFIDAVIT
I, Sarah Ransome, swear and affirm as follows...
Giuffre_Maxwell_Batch4_p00328.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 25 of 50
Defendant’s request for pediatric records is also overly-broad because, as this Court
correctly noted, Ms. Giuffre is not seeking damages based on anything prior to Defendant
abusing her. Defendant has told...
Giuffre_Maxwell_Batch4_p00349.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 46 of 50
these documents. And, again, Defendant puts forth no case law in support of her position to
compel. The Court should deny this request.
D. Request for Production No. 10
This request seeks the...
Giuffre_Maxwell_Batch4_p00374.png
Court Filing
Case 1:15-cv-07433-LAP Document 1328-21 Filed 01/05/24 Page 3 of 19
ROYAL PALM BEACH POLICE DEPARTMENT
Offense Report
Page:
Program:
Date: 4/25/16
Time: 8:52:07
Day Of Week . ;:
Occur From Date:
Dept Class ..:
Street Number :
City .....:
Zone/division :
Location Type
Report...
Giuffre_Maxwell_Batch4_p00603.png
Legal
Case 1:15-cv-07433-LAP Document 1328-41 Filed 01/05/24 Page 11 of 31
Dershowitz also misleadingly describes the Florida defamation action'® between himself
and Cassell and Edwards. Remarkably, Dershowitz fails to note that same documents he seeks
here (to use in the next installment of his...
Giuffre_Maxwell_Batch6_p00060.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 4 of 21
By and through her undersigned counsel, Ms. Giuffre hereby submits her Response in
Opposition to Defendant’s Motion for Sanctions. Defendant’s frivolous motion should be
denied. As part of a therapeutic exercise...
Giuffre_Maxwell_Batch6_p00067.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 11 of 21
violated no duty she directly owed to the Government, and thus violated no duty she (arguably)
indirectly owed to the Defendant.
Cc. There Was No Willful Destruction of Evidence
An additional reason for...
Giuffre_Maxwell_Batch6_p00373.png
Case 1:15-cv-07433-LAP Document 1331-36 Filed 01/05/24 Page 2 of 10
in response to questioning, and his assertion of the privilege at trial will be no less valid than it was
at his deposition. Under the circumstances of this case, this Court should not...
Giuffre_Maxwell_Batch5_p00216.png
Case 1:15-cv-07433-LAP Document 1330-15 Filed 01/05/24 Page 29 of 43
10.
ll.
12.
15,
16.
22.
Q. In June 2008, in open court. you pled guilty to two Florida State felonies,
correct? (/d. at 28.)
Other similar questions relating to the state crime...
Giuffre_Maxwell_Batch6_p00156.png
Flight Log
Case 1:15-cv-07433-LAP Document 1331-12 Filed 01/05/24 Page 8 of 10
case —<—$—$— CONFIDENTIAL
United States District Court
Southern District of New York
Virginia L. Giuffre,
Plaintiff, Case No.: 15-cv-07433-RWS
v
Ghislaine Maxwell,
Defendant.
AFFIDAVIT
I, Sarah Ransome, swear and affirm as...
Giuffre_Maxwell_Batch3_p00311.png
Case 1:15-cv-07433-LAP Document 1327-26 Filed 01/05/24 Page 5 of 27
She did not train Plaintiff to “recruit” other girls for massages or sexual massages. Id. at
81:21- 82:7.
She never arranged for or asked Plaintiff to have sex with anyone. Id...
Giuffre_Maxwell_Batch4_p00153.png
Legal
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 24 of 32
The motion in connection with which the Emails and the Reply Brief were submitted
concerns whether the Court should overrule a claim of privilege and compel testimony on pain of
contempt. See Fed...
Giuffre_Maxwell_Batch4_p00316.png
Case 1:15-cv-07433-LAP Document 1328-18 Filed 01/05/24 Page 13 of 50
However, to make a good faith effort of a response, Ms. Giuffre compiled many
examples of Defendant’s defamation, examples that were absent from Defendant’s brief, in
contravention of Rule 37.1...
Giuffre_Maxwell_Batch4_p00402.png
Court Filing
...Ede AUOb4ssshARsPocument 1328-22 Filed 01/05/24 Page 12 phg2 10 of 20
PALM BEACH COUNTY SHERIFF'S OFFICE PAGE 1
CASE NO. 98041883 SUPPLEMENT 4 OFFENSE REPORT CASE NO. 98041883
DISPOSITION: OPEN
DIVISION: DETECTIVE
911: N CONFIDENTIAL
SEXUAL BATTERY * * *
SIGNAL CODE: CRIME CODE: NON CRIME CODE: CODE: 110A...
Giuffre_Maxwell_Batch4_p00422.png
Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 10 of 22
Defendant also cites a decision from Judge Cote in Tyco Intern. Ltd. v. Walsh, which
allowed a delay in seeking discovery of financial information in that case because it was not
clear if...
Giuffre_Maxwell_Batch5_p00241.png
Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 11 of 17
(2d Cir. 2002)’, that authorize the giving of adverse-inference instructions on a finding of
negligence or gross negligence.” Fed. R. Civ. P. 37(e)(2) Advisory Committee's Note to 2015
Amendment...
Giuffre_Maxwell_Batch6_p00367.png
Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 7 of 11
DEFINITIONS
"Any" means any and all.
"You" or "Your" means Sarah Ransome, and anyone acting on Your behalf, and any
employee, agent, attorney, consultant, assignee, related entities or other representative of
You.
“Agent...
Giuffre_Maxwell_Batch3_p00220.png
Case 1:15-cv-07433-LAP Document 1327-14 Filed 01/05/24 Page 3 of 4
Common Words
You have included a number of words that relate to common items and place names. Please explain which RFP allows
for a search of the following terms:
50 — Southern District (which...
Giuffre_Maxwell_Batch4_p00142.png
Case 1:15-cv-07433-LAP Document 1328-6 Filed 01/05/24 Page 13 of 32
First, the Emails, consisting of one exchange dated May 10-11, 2011 and another dated
June 8, 2011, discuss, among other topics, Ms. Giuffre’s Manuscript, which purports to recount
her experiences with...
Giuffre_Maxwell_Batch6_p00364.png
Legal
Case 1:15-cv-07433-LAP Document 1331-35 Filed 01/05/24 Page 4 of 11
AO 88A (Rev. 12/13) Subpoena to Testify at a Deposition in a Civil Action
UNITED STATES DISTRICT COURT
for the
Southern District of New York
Virginia Giuffre
Plaintiff
v.
)
)
)
Ghislaine Maxwell ’
)
Civil...
Giuffre_Maxwell_Batch3_p00261.png
Court Filing
Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 18 of 21
show (1) that the party having control over the evidence had an obligation to timely produce it;
(2) that the party that failed to timely produce the evidence had ‘a culpable state of...
Giuffre_Maxwell_Batch6_p00073.png
Flight Log
Case 1:15-cv-07433-LAP Document 1331-4 Filed 01/05/24 Page 17 of 21
because it had not been previously notified of any injury that might reasonably lead to litigation
and no litigation had been threatened); Brigham Young Univ. v. Pfizer, Inc., 282 F.R.D. 566...
Giuffre_Maxwell_Batch6_p00103.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 14 of 21
Seguban, 54 F.3d 387, 391 (7th Cir.1995); Peiffer v. Lebanon Sch. Dist., 848 F.2d 44, 46 (3d
Cir.1988). Thus, silence can only result in any inference when it “is...
Giuffre_Maxwell_Batch6_p00305.png
Court Filing
Case 1:15-cv-07433-LAP Document 1331-30 Filed 01/05/24 Page 8 of 19
43 (1.e., Plaintiff Ransome)) claimed that Ms. Ransome’s experience (i.e. the basis for her claims
in Jane Doe 43) are “highly relevant” to this action. Presumably, Ms. Ransome’s testimony...
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