gov.uscourts.nysd.447706.851.0.pdf PDF
…I request that I approach the bench and 22 give you a few documents upon which these arguments are based. 23 I have four documents that I'm handing up. 24 I have to get a little bit into the…
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gov.uscourts.nysd.447706.961.0.pdf PDF
…however, seeks sanction against Ms. Giuffre’s counsel for their cautious approach. Ms. Maxwell takes the view that the confidential materials should have been 4 Case 1:15-cv-07433-LAP Document 961 Filed 12/12/18 Page 5…
gov.uscourts.nysd.447706.57.2.pdf PDF
…being misled by the proposed evidence. 26. I therefore approach this point on the footing that the normal starting point would be for appropriate relief to be granted to restrain the use of privileged material. So far as I have …
gov.uscourts.nysd.447706.561.0.pdf PDF
…excerpts which Defendant proposes to use. This Court has adopted a similar approach in many other cases when a party has proposed using depositions from an earlier action that the other parties have not had an opportunity to challenge. See…
gov.uscourts.nysd.447706.57.1.pdf PDF
…1976, was really the collection of evidence. One difficulty of this approach is to distinguish between one aspect and another: which is the important one? The answer here should therefore be that the real test here can be described as…
gov.uscourts.nysd.447706.1256.8.pdf PDF
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…
gov.uscourts.nysd.447706.1090.18.pdf PDF
…as Plaintiff now concedes. It read: “In 1999, Jane Doe #3 was approached by Ghislaine Maxwell,” and continuing that “Maxwell persuaded Jane Doe # 3 (who was only fifteen years old) to come to Epstein's mansion . . .” Plaintiff now concedes that…
gov.uscourts.nysd.447706.1256.11.pdf PDF
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…
gov.uscourts.nysd.447706.1206.2.pdf PDF
…Page 12 of 23 ” That the government claimed, indicated that the Nowhere did the government acknowledge that had in fact approached the prosecutors multiple times well bef…
gov.uscourts.nysd.447706.1328.5.pdf PDF
…based on this discovery, that she was not 15 years old, she now has conclusive proof that she was an underage minor when Ghislaine Maxwell approached her, recruited her, introduced her to Jeffrey Epstein, and sexually trafficked her as an…
gov.uscourts.nysd.447706.363.11.pdf PDF
…not “was wholly irrelevant” to Boies’s involvement in court. Separately, Dershowitz took issue with the way he said Boies’ firm approached him after Roberts’ claims first arose in late 2014. Dershowitz said that one of Boies Schiller’s lawyers…
gov.uscourts.nysd.447706.1307.4.pdf PDF
…7 Case 1:15-cv-07433-LAP Document 1307-4 Filed 08/25/23 Page 12 of 28 Whether it was a lie for Ms. Giuffre to say that Defendant approached females to bring them to Epstein. Id…
gov.uscourts.nysd.447706.1078.5.pdf PDF
…the property called 'Tuckedaway' was 'troubling'. They wrote that when the FBI arrived they were confronted by a locked gate which they forced their way through. The filing said: 'As the agents approached the front door to the main house…
gov.uscourts.nysd.447706.1343.1.pdf PDF
… Case 1:15-cv-07433-LAP Document 1343-1 Filed 01/26/24 Page 20 of 23 Page 207 1 G Maxwell - Confidential 2 obvious lie that you approached Virginia 3 while she was under age at Mar-a-Lago…
gov.uscourts.nysd.447706.1320.9.pdf PDF
…Jane Doe #3 would prove the following: In 1999, Jane Doe #3 was approached by Ghislaine Maxwell, one of the main women whom Epstein used to procure under-aged girls for sexual activities and a primary co-conspirator in his…
gov.uscourts.nysd.447706.1325.19.pdf PDF
…including the age and professional qualifications, of their employees. 10. Have you ever recruited, found, hired, approached, introduced, procured, or otherwise obtained, for the purposes of Jeffrey Epstein employing, any female who was not at the time a certified or…
gov.uscourts.nysd.447706.1331.36.pdf PDF
…the non-party witness in regard to the key facts and general subject matter of the litigation will likely inform the trial court whether the assertion of the privilege should be viewed as akin to testimony approaching admissibility under Fed…
gov.uscourts.nysd.447706.1320.10.pdf PDF
…Ms. Maxwell, a stranger to her, approached her on her college campus, and told her she would hire Ms. Sjoberg as her personal assistant. After Ms. Sjoberg began to work for Defendant inside the home she shared with Epstein, Defendant…
gov.uscourts.nysd.447706.1328.21.pdf PDF
…to have his friends go away. He says that he did. ~ l s osays that at this time he was also approached by his neighbor, who is a real estate agent and is selling his p a r ~ . …
gov.uscourts.nysd.447706.1320.24.pdf PDF
…commenced” . . . and the moving party “ha[d] not listed with specificity those individuals it wishes to depose.” Of course, neither of these points applies in this case at hand: the parties are approaching the close of fact discovery, and Ms…