…to and without waiving the above objections, Maxwell is withholding documents outside of the Relevant Periods described in paragraph15, supra, and is withholding production of documents that are privileged pursuant to a common interest agreement. B. Request No. 2 i. …
…unfavorable ....”). 1 In his motion, Epstein takes issue with the history of Ms. Giuffre’s attempts to get cooperation with service but the facts are simple, as the correspondence reflects, counsel reached out to counsel for Epstein back on March…
…videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles, contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes, reports and recordings of telephone or other conversations or communications, or of interviews or conferences, or of other meetings, occurrences…
…the work-prod u ctd octrine,Ru le 40 8 of the Fed eralRu les of E vid ence,any common interestprivilege,jointd efense agreementorany other applicable privilege. Case 1:15-cv-07433-LAP Document 79-2 Filed 04…
…already has sued Glenn Dubin, Epstein’s friend, had counsel who was totally cooperative in the rescheduling and reported fanciful and never-before heard claims about Ms. Maxwell, the Dubins and others that he has never reported to any law…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…Jane Doe No. 1 and Jane Doe No. 2 contacted Government counsel to request their agreement to add an additional victim to this case: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014,…
…2016, which is still pending. Needless to say, while the official discovery deadline has closed, certain depositions have been taken more recently due to issues with witness cooperation. Of course, if Defendant does not desire to take Ms. Ransome's…
…20 So, I think your Honor's suggestion makes some sense 21 but we did agree to the 12th and I am not backing out of that 22 agreement, certainly subject to comments by plaintiff's counsel 23 and the…
…First and foremost, the rule was intended to protect a litigant who provides limited amounts of information to government agencies under a confidentiality agreement to gain leniency from the government by demonstrating cooperation. Second, the rule addresses how the inadvertent…
…at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office defeming fedsral prosecution of Defendant Epstein and his numerous ceconspirators for identified federal sex crimes against more than 30 minors. 28…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…20 So, I think your Honor's suggestion makes some sense 21 but we did agree to the 12th and I am not backing out of that 22 agreement, certainly subject to comments by plaintiff's counsel 23 and the…
…21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney’s Office (Compl. ¶¶ 11-13)…
…the Court sees some merit to the process proposed by Ms. Giuffre, whereby the Court would select the most docket entries that involve the non-parties and would allow the parties to attempt to reach agreement on motions, (dkt. no…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…