1320-12.pdf PDF
… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179 Page…
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Found 208 results
for “exploited”
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1320-13.pdf PDF
…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …
gov.uscourts.nysd.447706.1218.22.pdf PDF
…07/15/21 Page 13 of 31 innocence. But this inference is inconsistent with Ms. Giuffre’s description of the manuscript, in which she explained “[n]ot everything in it is – not everything is in there . . ..” McCawley Dec. at 13…
gov.uscourts.nysd.447706.1331.7.pdf PDF
…Phillip Esplin, explained repeatedly that he could not respond to the questions posed because they were outside the scope of his opinion and there was insufficient information in the record to permit response. All of this testimony is irrelevant, more…
gov.uscourts.nysd.447706.57.3.pdf PDF
…the incident and fulfilled COMAH requirements. However, for the reasons already explained, those purposes were subsidiary and subservient to the dominant purpose as set out above.’ E 38. The letter also deals with other reports which it states were prepared…
gov.uscourts.nysd.447706.408.0.pdf PDF
…Sealed Exhibit 4. 27. As Mr. Edwards and I explained in the notice of withdrawal of this motion, “the withdrawal of the referenced filings is not intended to be, and should not be construed as being, an acknowledgement by Edwards…
gov.uscourts.nysd.447706.980.0.pdf PDF
…trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.” Id. As the Court of Appeals explained, a district court’s authority to oversee discovery and control the evidence introduced at trial is “ancillary to…
gov.uscourts.nysd.447706.233.0.pdf PDF
…s motion to have the recording of his deposition treated differently than the deposition of other witnesses should be denied. 5 III. Epstein’s Motion to Quash is Not Timely. As explained in the Motion for Alternative (DE 160), Ms…
gov.uscourts.nysd.447706.222.0.pdf PDF
…not allege a relationship in which Ms. Maxwell exercised control over Mr. Epstein or vice versa. Nor has plaintiff explained how Mr. Epstein’s assertion of his Fifth Amendment privilege will advance Ms. Maxwell’s interests in the outcome of…
gov.uscourts.nysd.447706.730.0.pdf PDF
…trial. B. EVEN IF TREATED AS HEARSAY, THE FBI 302 IS ADMISSIBLE PURSUANT TO RULE 803(8) AS A PUBLIC RECORD. For all the reasons just explained, the FBI 302 is not hearsay. Even if the Court were to regard…
gov.uscourts.nysd.447706.55.12.pdf PDF
…me to, if I wanted to 16 Q. Okay. And how was it explained to you that 17 be his employee, because I was going from one house to 17 you were now to deal with Ms. Maxwell, as opposed…
gov.uscourts.nysd.447706.56.0.pdf PDF
…the application of the choice-of-law test cited by defendant. In Astra Aktiebolag v. Andrx Pharm., Inc., the court explained, “[w]here, as here, alleged privileged communications took place in a foreign country or involved foreign attorneys or proceedings…
gov.uscourts.nysd.447706.535.0.pdf PDF
…As the Court is aware, the issue of in a defamation case is a matter left to the jury. As the Bouveng Court recently explained, “The unique nature of [defamation] cases is well established. ‘In actions for other torts there…
gov.uscourts.nysd.447706.320.0.pdf PDF
…original search resulted in approximately 9,000 documents and communications containing one or more term in the content or meta-data. The volume of the documents is explained by the breadth of the terms searched, resulting in pulling non-relevant…
gov.uscourts.nysd.447706.968.0_1.pdf PDF
…did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon.36 Indeed…
gov.uscourts.nysd.447706.978.0.pdf PDF
…did not rely on them in adjudicating a motion, this was legal error. As explained above, the proper inquiry is whether the documents are relevant to the performance of the judicial function, not whether they were relied upon.36 Indeed…
gov.uscourts.nysd.447706.993.0.pdf PDF
…the linked documents,” suggesting that the Court either never received or did not review the materials provided. Id. This is patently untrue. As Giuffre explained in her September 20, 2019, letter, “Judge Sweet actively reviewed the materials submitted.” Dkt. 988…
gov.uscourts.nysd.447706.1137.19_2.pdf PDF
…would either enable or require her to do so.” Id. Plaintiff never responded. She also has not explained when or how Ms. Maxwell “acknowledged” her “plans to call Mr. Gow for testimony at trial,” nor why that is relevant to…
gov.uscourts.nysd.447706.936.0.pdf PDF
…crime victims, the majority of the materials sought here can and should be disclosed. For these reasons, explained in further detail below, the Miami Herald respectfully requests that the Court unseal all sealed files on the docket, and remove any…
gov.uscourts.nysd.447706.185.8.pdf PDF
…the Joinder Motion), Giuffre gave an interview to the Daily Mail, a British tabloid publication, in which she described in detail how she was purportedly recruited by Epstein for sexual exploitation. See Daily Mail Article dated March 5, 2011, attached …