…Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley…
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley…
…denial comes after two Sunday papers in Britain published interviews with the woman in which she claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three times between 1999 and 2002…
…produce clear and convincing evidence of its falsity. ........................................................... 56 1. The January 2015 statement accurately denied that Ms. Maxwell met Plaintiff when Plaintiff was 15 years old in 1999. ..................…
…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…
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999 and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
…1986) ............................................................................................... 11 Granite Partners, L.P. v. Bear Stearns & Co. Inc., 184 F.R.D. 49 (S.D.N.Y.1999) ................................................................................................. 11 Guiffre v. Maxwell, 2016 WL 1756918 (S.D.N.Y…
…lawsuit presents one relatively simple question: is Plaintiff’s claim that she was sexually abused, sexually trafficked and held as a “sex slave” by Jeffrey Epstein between 1999 and 2002 “with the assistance and participation of” Ms. Maxwell substantially true…
…Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley…
…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: …
…2016 hearing on Ms. Maxwell’s Motion to Compel, the Court clearly Ordered Plaintiff to disclose all of her treating health care providers since 1999 and produce their records. Plaintiff did not do so, and still has not provided this…
…wit, that Ms. Maxwell “assisted” and participated in sexual abuse of the Plaintiff between 1999 and 2002. Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any contact with Ms. Maxwell after 2002. Indeed…
…2016 hearing on Ms. Maxwell’s Motion to Compel, the Court clearly Ordered Plaintiff to disclose all of her treating health care providers since 1999 and produce their records. Plaintiff did not do so, and still has not provided this…
…R.D. 190 (W.D.N.Y. 2005) ............................... 10 Kolenc v. Bellizzi, No. 95 CIV. 4494 (LMM KNF), 1999 WL 92604 (S.D.N.Y. Feb. 22, 1999) .. 8 Lyman v. Felter, No. 1:12-CV-530 MAD/RFT, 2015…
…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…
…Yetev Lev D'Satmar, Inc., 265 A.D. 2d 360, 696 N.Y.S. 2d 496 (2d Dep't. 1999) .............................................................12 Brooks v. Macy's, Inc., No. 10 CIV 5304 (BSJ/HBP), 2010 WL 5297756 (S.D.N.Y. Dec…
…2016 hearing on Ms. Maxwell’s Motion to Compel, the Court clearly Ordered Plaintiff to disclose all of her treating health care providers since 1999 and produce their records. Plaintiff did not do so, and still has not provided this…
…wit, that Ms. Maxwell “assisted” and participated in sexual abuse of the Plaintiff between 1999 and 2002. Plaintiff does not claim that any sexual abuse occurred after 2002 or that she had any contact with Ms. Maxwell after 2002. Indeed…
…2 United States v. Duncan, 42 F.3d 97 (2d Cir.1994)................................................................................................................... 2 United States v. Lumpkin, 192 F.3d 280 (2d Cir.1999)...............................................................................................................…
…Notably, the police report documents that neither the residences she was moving from or to involved the apartment Plaintiff claims was rented for her by Jeffrey Epstein and where she testified she lived exclusively from June 1999 until September 2002…
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