…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…
…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…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…Courts Substance or procedure; determinativeness Federal courts sitting in diversity apply state Synopsis substantive law and federal procedur…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…aware, Ms. Giuffre has alleged that Defendant defamed her when she called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of Defendant and Defendant’s long-time boyfriend, convicted…
…EVID. 405(B) REQUIRES ADMISSION OF ALL SPECIFIC INCIDENTS OF PLAINTIFF LYING OR ENGAGING IN DECEITFUL OR FRAUDULENT CONDUCT 1 A. All allegations or comments made by Plaintiff are “connected to” the alleged defamatory statement.........................................................................................…
…AUTHORITIES ...................................................................................................... iii-v PRELIMINARY STATEMENT .....................................................................................................1 FACTUAL AND PROCEDURAL BACKGROUND...................................................................…
…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…
…Intervenor Dershowitz’s letter (DE 956) filed on December 3, 2018. Intervenor Dershowitz has made serious allegations against Plaintiff and her counsel regarding an alleged leak of sealed materials. Because Intervenor Dershowitz has failed to provide any details whatsoever concerning…
…Introduction 1. Ghislaine Maxwell did not participate in, facilitate, manage or otherwise conspire to commit sex trafficking as alleged by Plaintiff Virginia Roberts Giuffre (“Giuffre”). Giuffre’s unsubstantiated allegations concerning Ms. Maxwell are false. Giuffre’s fantastical claims, contained in…
…in London after visiting his father Prince Philip. (AP) Buckingham Palace officials have again denied claims made by a woman who alleged that she was forced to have sex while underage with Prince Andrew, Duke of York. The second denial…
…direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation of each category of damage alleged, and the existence…
…or produce records is demonstrably inaccurate. In light of your representations to the Court regarding the allegedly diligent efforts to identify all health care providers and provide documents compelled by the Court, please provide us with a printout of all…
…the purpose of moving to unseal and make public a hypothetical set of documents that TGP speculates identify a group of non-parties in this action who allegedly “abused girls trafficked by Jeffrey Epstein and Defendant Maxwell.” See DE 1258…
…she was being held captive Asked other women if they knew anyone 'slutty' to bring to Epstein Would allegedly use cash she gained from sex to live a luxury lifestyle By Wills Robinson For Dailymail.com Published: 12:49 EDT…
…self-serving affidavit by her attorney Philip Barden in support of her motion for Summary Judgment that discussed Mr. Barden’s “intent” in allegedly being the main drafter of Defendant’s January 2, 2015 press release. (DE 586 at p…
…s]
assistance, [Epstein] converted [Plaintiff] into what is commonly referred
to as a ‘sex slave.’” ................................................................................... 59
4. The January 2015 statement accurately reported that Plaintiff
…identical to this one. Since at least 2011 plaintiff has been selling her story to the media, telling ever more salacious stories about her alleged sexual encounters with ever more prominent men. Whenever anyone denies her allegations, she and her…
…discovery based upon the representation or understanding that the discovery would be subject to the Protective Order previously issued in this action; (b) persons who are identified as having allegedly engaged in sexual acts with Plaintiff, or other alleged victims…
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