…and in response to a pleading in which the lawyers for Jane Doe #3, without benefit of an affidavit, leveled totally false and outrageous charges against me that have been reported around the world and threaten to damage my reputation…
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell c/o Laura A. Menninger, Esq…
…This is Judge Netburn. I 3 have you here with my law clerk and with a court reporter. 4 What I'm going to ask is that each party state its 5 appearance for the record, and then if I…
…permitted to impose an unnecessary burden upon Mr. Wexner and many others for purposes of staging a collateral attack on the credibility of Ms. Giuffre with extrinsic evidence. We submit there is no basis for compelling Mr. Wexner’s deposition. …
…among other things, calling Giuffre a liar in published statements with the malicious intent of discrediting and further damaging Giuffre worldwide. JURISDICTION AND VENUE 2. This is an action for damages in an amount in excess of the minimum jurisdictional…
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