…cv-07433-LAP Document 1295-2 Filed 12/12/22 Page 2 of 12 hundreds of young girls who came and went from the home she shared with Epstein. Her testimony is directly refuted by multiple witnesses. Chillingly, Rinaldo Rizzo…
…the March 31, 2020 telephone conference, to identify the first five motions for the unsealing process. The Original Parties have met and conferred multiple times to propose five motions pertaining to J. Doe 1 and J. Doe 2, as identified…
…agent, Ross Gow, who is a key witness in this case because he issued, on Defendant’s behalf, one of the defamatory statements at issue to multiple media outlets. Defendant’s counsel, Philip Barden, is also counsel for Mr. Gow…
…with Plaintiff Virginia Giuffre at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI 302 attached hereto as Exhibit A. On March 18…
…OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to…
…Repeated Disregard for this Court’s Order Supports An Adverse Inference Ms. Giuffre does not want to burden the Court with unnecessary briefing on a topic that has been argued multiple times. See Docket Entry 96 (Motion for Forensic Examination)…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…For example, non-party Ransome witnessed the following: Q. And when you say you were on rotation, you mean you were having sex with Jeffrey multiple times per day? A. No. As when I was finished another girl was called…
…financier Jeffrey Epstein. (Accused of having sexual relations with multiple underage girls, Epstein ultimately pleaded guilty to just a single state charge of soliciting prostitution.) Case 1:15-cv-07433-LAP Document 363-11 Filed 08/11/16 Page…
…modification. In contrast, there are compelling reasons to maintain the Protective Order, the modification of which is “perilous for multiple reasons,” including that such modifications “undermine confidence in protective orders” and may well subject individuals to “annoyance, embarrassment, oppression, or…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…to documents that may be released, they should not receive a second opportunity to object thereafter. Allowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process. The same is true of…
…that you use "wildcards" to ensure that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by "replacing" single or multiple characters.) Where there are a specific number of characters needed to be included…
…Doc.892, at 4-10. It found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails,” and “[t]hird-party witnesses have…
…2021 letter. See DE 237. They do so in multiple respects. First, the parties seek to clarify the term “non-party Does” as it appears in the January 6 Order. This purported ambiguity is just a pretext to again request…
…And for 8 the record, she is an absolute total liar and 9 you all know she lied on multiple things and 10 that is just one other disgusting thing she 11 added. 12 Q. Did you help her obtain…
…her proposal (and the status quo) require far more duplication and therefore more work, absorbing more of her counsel’s time. If the Does continue to be split into multiple groups with multiple rounds of reviews, as Ms. Maxwell proposes…
…the Court’s order, Ms. Giuffre effected alternative service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways, all calculated to give her actual notice of the subpoena. See Schultz Decl. at Composite Exhibit 1…
…also a key topic in this litigation: Defendant’s defamation of Ms. Giuffre through the media. Multiple documents show Epstein’s involvement in crafting Defendant’s various draft statements to the media concerning Ms. Giuffre, and one of the late …
…terms “confidentiality agreements” and “associated entity” are vague, undefined and susceptible of multiple meanings and definitions Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying…
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