321 results for "January 24 2015"
Page 8 of 13
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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 9 of 34
Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Plaintiffs’ Motion to Compel Production of Documents
FACTUAL BACKGROUND
On December 30, 2014, Jane Doe No. 3 filed a motion (and...
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...Luke Harding, “Georgia Angered by Russia-Abkhazia Military Agreement,” Guardian, November 24, 2014,
https://www.theguardian.com/world/2014/nov/25/georgia-russia-abkhazia-military-agreement-putin.
16. Adrian Croft, “Russia Could Soon Run Multiple Ukraine-Sized Operations: U.S. General,” Reuters, January 16, 2015, http://www.
reuters.com/article...
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...2016. (Doc. #13) On November 30, 2015, contemporaneous with the filing
of her Rule 12(b) Motion to Dismiss, Ms. Maxwell also requested of this Court a stay of
discovery pursuant to Rule 26(c). (Doc. #17) That motion was denied on January 20, 2016, with
an additional two-week...
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Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 8 of 21
Indeed, Defendant retained counsel to further assist Mr. Gow:
Q. Did you authorize Ross Gow to issue that statement on your behalf in January of
2015?
A. Lalready testified that that was done...
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...23 Filed 01/05/24 Page 20 of 22
issues. And because of concern that the Defendant is concealing assets, she should also be
required to reveal all significant (greater than $10,000) assets or other monetary transfers in since
the beginning of January 1, 2015, as well as all...
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...The January 2, 2015, communication by Ross Gow to members of the British media did not, nor
was it likely to, cause serious harm to the reputation of Plaintiff. The imputation conveyed by
the communication is substantially true. Substantial portions of the communication conveyed
honest opinion. The communication was privileged...
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...Did you send it on January 2nd, 2015?
A. I believe I did.
Q. When you sent that email were you acting
pursuant to Ms. Maxwell's retention of your services?
A. Yes, I was.
Q. Could you please tell me everything you know
about Virginia Roberts Guiffre.
MS. MENNINGER...
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...In about early January 2015, following the filing of Ms. Giuffre’s motion to join
the CVRA case, Dershowitz launched a media attack not only on Ms. Giuffre but also on Mr.
Edwards and me. Dershowitz repeatedly and publicly attacked the two of us, saying such things
as “if these...
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...Friday, January 16, 2015 7:56 PM
To: jeffrey E.
Subject: Re: How are you holding up?
Importance: High
that is old news -- buy dollar and take a nap? Kind of like buying Apple?
On Fri, Jan 16, 2015 at 2:52 PM, jeffrey E. wrote:
it...
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...W at § 4-5 (Declaration of Virginia Roberts,
January 21, 2015).
60. She also asserted that when she “was approximately 15 or 16 years old”
when Mr. Epstein and Ms. Maxwell began trafficking her to Epstein’s acquaintances. These
statements are disproven by documentary evidence, and Ms. Giuffre has herself...
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Case 1:15-cv-07433-LAP Document 1330-20 Filed 01/05/24 Page 4 of 10
From:
Sent: Friday, January 02, 2015 10:07 AM
To: G Max
Subject: Fw: The Times - David Brown
Hi Ghislaine
The Times and the BBC having rung suggesting there are 'fresh' allegations by...
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...from
May 24, 2016, Deposition of Lynn Trude Miller.
11. Attac
hed hereto as Sealed Exhibit 9 are true and correct copies of flight logs
excerpted Rodgers Dep. Ex. 1.
12. Attac
hed hereto as Sealed Exhibit 10 is a true and correct copy of January 22,
2015 Dailymail.co...
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Case 9:08-cv-80736-KAM Document 319-1 Entered on FLSD Docket 03/24/2015 Page 10 of
34
Edwards, Bradley vs. Dershowitz
Case No.: CACE 15-000072
Plaintiffs’ Motion to Compel Production of Documents
http:/Awww.cnn.com/videos/world/2015/01/05/wm-uk-sex-abuse-allegations...
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...24 Page 15 of 25
DOCUMENT REQUEST NO. 25
Produce all bank statements or other financial statements which were prepared by You,
on Your behalf or by or on behalf of any entity in which You held an ownership interest of 10%
or more at any time from January 2015...
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...Identify all communications you have had with Jeffrey Epstein since January 1,
2015, and the substance of those communications.
ANSWER:
Ms. Maxwell objects to this Interrogatory on the grounds that it is overly broad and unduly
burdensome and calls for information that is irrelevant to this action and not reasonably...
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Case 1:15-cv-07433-LAP Document 1320-18 Filed 01/03/24 Page 23 of 40
Ex. 6 at 3. As the briefing on the issue continued, in an October 26, 2015 response filing,
Dershowitz argued that Ms. Giuffre’s public statements waived the privilege,’ along with
actions by...
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...Giuffre published on that
domain from 2 January 2015 to the date that I filed this report”.
Domain Unique | Number of
Domain Visitor Traffic Articles
Dail Published
| 1 [http://beforeitsnewscom 193,333
| 2 http://boltonbnp.blogspotcom®
3 [np:/fousinessnewsusa.org’
[4 [hp /duketindufuth.com? >
| 5 [http://dukefmfargocom’
| 6 [ http://homebtcom...
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Case 1:15-cv-07433-LAP Document 1330-17 Filed 01/05/24 Page 4 of 12
The Motion is untimely and no special circumstance exists, nor have any been claimed, requiring
denial of the motion.
B. November 2015 Communication from Mr. Gow Concerning a Press Inquiry
is Cumulative and...
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...Attached hereto as Sealed Exhibit 26 is a true and correct copy of January 2,
2015, Email Correspondence (GM_ 00068).
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Case 1:15-cv-07433-LAP Document 1332-11 Filed 01/08/24 Page 4 of 9
Communic ’ns Co. v. Comcast Cable Communic ’ns, LLC, Nos. 11-2684-, 11-2685- & 11-2686-
JWL, 2015WL11122119, at 1 (D. Kan. Apr. 21, 2015).
The Motion to Compel is an example of...
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...42
Produce all policies of insurance having any cash value that exist or existed from January
2015 to the present, which policies You or any entity controlled by You is the owner or
beneficiary.
RESPONSE: Ms. Maxwell objects to this Request on the grounds that it is overly broad
and...
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...Sir, I want to represent to you that on
about January 2nd, 2015, Defendant Maxwell released a
statement that said, "The allegations made by
Virginia Roberts against Ghislaine Maxwell are
untrue."
That was a false statement, right?
MR. PAGLIUCA: Object to form and
foundation.
THE WITNESS: Fifth.
BY MR. CASSELL...
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Case 1:15-cv-07433-LAP Document 1320-17 Filed 01/03/24 Page 16 of 25
You or on which You hold a right or have held a right to withdraw funds at any time from
January 2015 to the present.
RESPONSE: Ms. Maxwell objects to this Request on...
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...As the Court can see from this very simple comparison,
anyone with half a brain in January of 2015 could take a look
at column 1 and look at column 2 and decide that the original
allegations are either true or they are false; the new
allegations are either true...
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...40
Produce all copies of any and all brokerage account statements or securities owned by
You individually, jointly with any person or entity or as trustee, guardian or custodian, from
January 2015 to the present, including in such records date of purchase and amounts paid for
such securities, and certificates...
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