…that this request is overly broad and unduly burdensome. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of…
…37 Filed 01/03/24 Page 14 of 48 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of…
…3 Filed 03/23/16 Page 12 of 40 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of…
…by newspaper and other media outlets internationally, and they were, in fact, published globally, including within the Southern District of New York. 10. Maxwell’s false statements constitute libel per se inasmuch as they exposed Giuffre to public contempt, ridicule…
…3 Filed 06/21/16 Page 14 of 48 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of…
…by newspaper and other media outlets internationally, and they were, in fact, published globally, including within the Southern District of New York. 10. Maxwell’s false statements constitute libel per se inasmuch as they exposed Giuffre to public contempt, ridicule…
…New Mexico; (d) U.S. Virgin islands; (e) any jet or aircraft owned or controlled by Jeffrey Epstein. Request Number 33 appears to be subsumed by the globally inclusive, unrestricted Request Number 8. Both requests fail in many ways. First…
…https://www.dailymail.co.uk/news/article-8872327/Jeffrey-Epstein-told-Ghislaine-Maxwell-reward-discredit-Virginia-Roberts.html 104 https://globalnews.ca/news/7412928/ghislaine-maxwell-transcript-jeffrey-epstein/ 105 https://in.reuters.com/article/people-ghislaine-maxwell/ghislaine-maxwell…
…For instance, Interrogatory No. 6 directs Ms. Giuffre to “[i]dentify any ‘false statements’ attributed to Ghislaine Maxwell which were ‘published globally’ … as You contend in … Your Complaint[.]” Interrogatory No. 8 directs Ms. Giuffre to identify, among other…
…5 In my view, your Honor, there should be -- the parties 6 should identify globally what I would call category one, 7 category two and category three documents. Category one would 8 be non-judicial documents; category two would be…
…propounded discovery. 15 Case 1:15-cv-07433-LAP Document 75 Filed 03/31/16 Page 21 of 31 information that she has globally shared and sold to media publications or is actively trying to sell for a profit…
…claims.”). Interrogatory No. 6. Identify any “false statements” attributed to Ghislaine Maxwell which were “published globally, including within the Southern District of New York” as You contend in paragraph 9 of Count 1 of Your Complaint, including: a. the exact…
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