… Verbatim Statement of Request No. 1: All documents relating to communications with Jeffery Epstein from 1999 – Present ii. Maxwell’s Response: Maxwell objects to this Request on the grounds that it is overly broad and unduly burdensome and calls for…
…files this Reply in Support of her Motion to Compel Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction. This Court Ordered Defendant to search for and produce documents from all her email accounts from 1999-present…
…r. 32.7 – Control of Major Hazard Regulations 1999. This was an application by the third party (TAV) for specific disclosure of documents over which the defendants had asserted litigation privilege. E The proceedings arose out of the explosion and…
…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…
…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…
…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…
…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…
… Ms. Giuffre Has Answered This Interrogatory Completely .....................10 2. This Court Has Already Ruled Against Defendant on Pre-1999 Medical Records, so Defendant is Estopped From Bringing This Argument .........................…
…by Ghislaine Maxwell and Jeffrey Epstein when Giuffre was under the age of eighteen. 9. Between 1999 and 2002, with the assistance and participation of Maxwell, Epstein sexually abused Giuffre at numerous locations including his mansions in West Palm Beach…
…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…
…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…
…Yetev Lev D'Satmar, Inc., 265 A.D.2d 360, 696 N.Y.S.2d 496 (2d Dep't. 1999) ...............................................................10 Caplan v. Winslet, 218 A.D.2d 148, 637 N.Y.S.2d 967 (1996)...............................................................................15 Catalanello v. Kramer, …
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