…The defense intends to show that Plaintiff for financial and other improper reasons manufactured her allegations of “sex trafficking” and created from whole cloth her alleged $30 million in noneconomic damages from “defamation.” Some of the most relevant and material…
…of 7 fabricating stories? Has she participated in other litigation? 8 Does she have a motive to depart from the truth for financial 9 gain? Over the last ten years has she mentioned these 10 allegations to anyone? Who are…
…1986)). Amodeo I found instructive F.T.C. v. Standard 9 Case 1:15-cv-07433-LAP Document 1057 Filed 06/10/20 Page 11 of 17 Financial Management Corp., 830 F.2d 404 (1st Cir. 1987). In F…
…abuse of Ms. Giuffre, Ms. Giuffre has long been attempting to depose him in the action. Epstein, who is generally regarded as having vast financial resources, evaded those efforts to be served. Accordingly, on May 25, 2016, Ms. Giuffre sought…
…was convicted after a public trial; classes of victims have litigated public lawsuits against Jeffrey Epstein and his co-conspirators (including against several of his financial institutions); and the public and its elected officials have made uncovering details about Epstein…
…Exhibit REDACTED, # 14 Exhibit REDACTED, # 15 Exhibit REDACTED, # 16 Exhibit REDACTED) Motion to Compel MOTION for Protective Order (REDACTED) Regarding 08/12/2016 370 Personal…
…time. I watched them both ejaculate with each other. They were having quite a good time together.) Ransome Dep. Tr. at 234-235 (Q. Did you apply for any financial aid for FIT? A. No. Jeffrey was covering FIT. Q…
…10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that…
…that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact…
…10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that…
…DOCUMENT REQUEST NO. 21 Produce all copies of the complaints in any lawsuits that You have filed in any court in which You seek damages or any other financial recovery from 2014 to the present. RESPONSE: Ms. Maxwell objects to…
…personal, political, and financial gain, as well as to obtain potential blackmail information. One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was former Harvard Law Professor Alan Dershowitz, a close friend…
…worked for or been in control of Ms. Maxwell. x Ms. Maxwell and Mr. Epstein have had no financial, professional or employment relationship in more than a decade, many years before 2015 when the purportedly defamatory statement was published. Ms…
…an adverse inference. Likewise, Mr. Epstein has no stake in the outcome of this litigation, financial or otherwise. Nor has he participated in this litigation in anyway. Rather, he completely refused to participate, moving to quash his deposition, pleading the…
…If HOSL alone is responsible for the incident, the joint venture arrangements may mean that 40% of the financial consequences will ultimately be borne by Chevron. G 3. TAV Engineering Ltd (‘TAV’) is the engineering company which designed and manufactured…
…10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that…
…Conveniently, Epstein does not bother to discuss this factor. Presumably this is because of the exceedingly close personal, financial, and social relationships (among other things) between himself and Defendant Maxwell. Defendant is his former girlfriend. She was also his partner…
…party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)). Furthermore…
…10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that…
…19 object on behalf of the 20 plaintiff, Virginia Giuffre, to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked…