giuffre-maxwell
gov.uscourts.nysd.447706.103.2
3 pg
…the Southern District of Florida (the “Office”), the Office was recused by the Department of
Justice from prospective responsibility for any criminal investigation or potential prosecution
relating to Jeffrey Epstein’s alleged sexual activities with minor females. As a result…
giuffre-maxwell
gov.uscourts.nysd.447706.102.0
9 pg
…in which she works – the U.S.
Attorney’s Office for the Southern District of Florida – has been recused by the Justice
Department “from prospective responsibility for any criminal investigation or potential
prosecution relating to Jeffrey Epstein’s alleged sexual…
giuffre-maxwell
gov.uscourts.nysd.447706.91.0
3 pg
…example, a “public interest privilege” which is unavailable to individual, non-governmental
litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they
comply with the Federal and Local Rules).
Because of the breadth of the issues raised, Defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…INTRODUCTION .......................................................................................................................... 1
I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG,
RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1
II. MS. RANSOME REFU…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…Defendant refused to answer questions that go to heart of the type of questions
this Court specifically ordered Defendant to answer: they could not be more on-point.
None of Defendant’s arguments change the language of this Court’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…INTRODUCTION .......................................................................................................................... 1
I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG,
RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1
II. MS. RANSOME REFU…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly ·'adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly “adult” sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
1320-6
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
1320-2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…Defendant refused to answer questions that go to heart of the type of questions
this Court specifically ordered Defendant to answer: they could not be more on-point.
None of Defendant’s arguments change the language of this Court’s…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.22
17 pg
…264-1). Yet,
during her second deposition, Defendant again refused to answer numerous questions regarding
sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the
Court should direct her to fully answer the relevant questions…
giuffre-maxwell
gov.uscourts.nysd.447706.363.5
6 pg
…Check one:
By handing it to a person identified to me as the Witness or by leaving it with the Witness who refused service.
I attempted to serve the Witness on _______ occasions but have not been able to…
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