…the broad scope of materials requested, most of which seeks information that is irrelevant to the Defamation Action and clearly intended solely to harass, embarrass, intimidate, and oppress this non-party by seeking highly personal and sensitive information. 2. Ransome…
…the broad scope of materials requested, most of which seeks information that is irrelevant to the Defamation Action and clearly intended solely to harass, embarrass, intimidate, and oppress this non-party by seeking highly personal and sensitive information. 2. Ransome…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…clearly asked solely for the purpose of embarrassing, intimidating and harassing a non-party already fearful for her safety and life based upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she testified…
…pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. …
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…pictures of Jane Doe 43 after a 6 Case 1:15-cv-07433-LAP Document 1332-15 Filed 01/08/24 Page 7 of 11 suicide attempt. Those could only be used to publicly humiliate and intimidate her. Again…
…3 the allegation is made for an improper purpose, in other words, 4 if it is made for a wrongful purpose or to harass or seek to 5 press or intimidate the victim, then it is not something that 6…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…3 the allegation is made for an improper purpose, in other words, 4 if it is made for a wrongful purpose or to harass or seek to 5 press or intimidate the victim, then it is not something that 6…
…found her and we served her and now she’ll be subjected to a deposition.”38 By his own words, Dershowitz wants to intimidate and harass Ms. Giuffre with the specter of his sending her “to jail.”39 Even Dershowitz…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…Edwards’ court response: the suit was filed “for the sole purpose of attempting to intimidate” him and his client. 2/4 Case 1:15-cv-07433-LAP Document 773-4 Filed 03/23/17 Page 4 of 5 Epstein…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…documents pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a victim of sexual trafficking…
…Further, Plaintiff misstates the law when she claims to defeat the privilege through her naked assertion that the intent of the statements were “to bully, harass and intimidate the Defendant” Pl’s Opp’n at 9. Indeed, the Khalil court…
…2015. By his own words, Dershowitz wanted to intimidate and harass Ms. Giuffre with the specter of his sending her “to jail.” Aligned in purpose, Cernovich and Dershowitz’s motivations are equally illegitimate. Here Cernovich is someone who is a…
…are protected by a qualified privilege unless the statements were made with the intent to “bully, harass, or intimidate” their adversaries. True to form, Plaintiff baldly asserts that the Statement here was made “for an inappropriate purpose, to bully, harass…
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