…C ou rt’s A pril21,2016,ru lingM s.Giu ffre has mad e significantefforts to try to trackd own and collectany med icalrecord she can find from 1999 to the present,inclu d ingpayingall fees associated withthatcollection process…
…01/08/24 Page 3 of 42 Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account…
…07/15/21 Page 2 of 12 Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account…
…nor produce documents from it. Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account to…
…routinely grant extensions of time of deadlines when awaiting Hague Convention service, and the facts and circumstances in this case call for the same. Daly v. Llanes, 1999 WL 259507, (S.D.N.Y. April 30, 1999), is perfectly illustrative: …
…her agent, associate, employee or assignee. 3. “Your Attorneys” includes any attorney who You have engaged to represent You, whether for remuneration or pro bono, from 1999 until today, including without limitation, David Boies, Paul Cassells, Bradley Edwards, Spencer Kuvin…
…2016) ............................ 1,2,3 Quantachrome Corp. v. Micromeritics Instrument Corp., 189 F.R.D. 697, 701 (S.D. Fla. 1999)10 Redwood v. Dobson, 476 F.3d 462, 467-68 (7th Cir. 2007) ........................................................... 9 Vincent v. Mortman, No. 04 Civ…
…at #16-21 and 75-77. To the extent those initials represent people from whom you have requested all communications (and which the Court has limited to 1999-2002 and post-2002 as they relate to sex trafficking), for example…
…matter was completed, 1 Ms. Giuffre proposes the following instruction: Defendant had a duty to collect and produce relevant data from her email accounts from 1999 to the present. Defendant failed to collect and produce relevant emails from some of…
…nor produce documents from it. Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account to…
…2/31. The Joinder Motion alleges that Plaintiff met Epstein in 1999, when she was 15. Both the year and the time of year are material to this case. Plaintiff now admits that she did not meet Epstein in 1999…
…at #16-21 and 75-77. To the extent those initials represent people from whom you have requested all communications (and which the Court has limited to 1999-2002 and post-2002 as they relate to sex trafficking), for example…
…Exhibit A. Response to Interrogatory No. 12 Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care providers from 1999 through the present. Ms. Giuffre continues to search for medical providers that appear in documents. ! Dr…
…Epstein, and why hasn’t that account been disclosed and searched? This Court should order Defendant to disclose all email accounts she has used from 1999 to the present. 11 At any rate, both recent testimony in this case…
…1996 - present. 8. All documents relating to Gh islaine Manvell from 1996- present. 9. All documents relating to communications with any of the folio-wing indivi
…does not seek and does not require the production of multiple copies of identical Documents. 9. Unless otherwise specified, the time frame of this request is from 1999 to present. I 0. This Request is deemed to be continuing. If…
…Epstein, and why hasn’t that account been disclosed and searched? This Court should order Defendant to disclose all email accounts she has used from 1999 to the present. 11 At any rate, both recent testimony in this case…
…Exhibit A. Response to Interrogatory No. 12 Pursuant to this Court’s Order, Ms. Giuffre will provide information for health care providers from 1999 through the present. Ms. Giuffre continues to search for medical providers that appear in documents. ! Dr…
…Ms. Giuffre recalls one facility named “Growing Together” that was located in or around Palm Beach, but she does not recall the dates when she resided at the facility. From 1999-2002, Ms. Giuffre lived and travelled with Jeffrey…
…or any of her attorneys, agents, investigators, from the period 1999-present. 2. All fee agreements for Your engagements with any attorneys for the purpose of pursuing any civil or criminal claims regarding Jeffrey Epstein, Ghislaine Maxwell, 29. A copy…
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