…ereached: 1. Iw illendeavortohavem y clientgainaccesstoanearthlinkaccountthatyou believeishers.Yourbasisforthat beliefisadiskyou produced lastw eek,obtained pursuanttoaFO IA request,thatcontained atP age2035 an addressbookfrom approxim ately 2005 w hichhasthatearthlinkaccountnam enexttoM s.M axw ell’snam e. 2. T er…
…of documents over which the defendants had asserted litigation privilege. E The proceedings arose out of the explosion and fire at the Buncefield Oil Terminal in Hertfordshire in December 2005. The fire engulfed a large proportion of the terminal’s…
…ereached: 1. Iw illendeavortohavem y clientgainaccesstoanearthlinkaccountthatyou believeishers.Yourbasisforthat beliefisadiskyou produced lastw eek,obtained pursuanttoaFO IA request,thatcontained atP age2035 an addressbookfrom approxim ately 2005 w hichhasthatearthlinkaccountnam enexttoM s.M axw ell’snam e. 2. T er…
… Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from Juan Alessi’s November 21, 2005 Sworn Statement. 8. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the September 8…
… Attached hereto as Exhibit 5, is a true and correct copy of Excerpts from Juan Alessi’s November 21, 2005 Sworn Statement. 8. Attached hereto as Exhibit 6, is a true and correct copy of Excerpts from the September 8…
…2006) ............................. 8 Jones v. J.C. Penny’s Dep’t Stores, Inc., 228 F.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…
…fo1111. 12 Q And E.W. is somebody you observed nt 12 A Fifth. 13 Jeffrey Epstein's house on more than 100 13 Q During your lnternction with nndernge 14 occasions between 2002 and 2005, n time period 14…
…Report. 10. Attached hereto as Exhibit 8, is a true and correct copy of the November 21, 2005 Sworn Statement of Juan Alessi. 11. Attached hereto as Exhibit 9, is a true and correct copy of the May 4, 2016…
…0 CONCLUSION.................................................................................................................. 10
ii
TABLE OF AUTHORITIES
CASES
AT & T Corp. v. Sprint Corp.,
407 F.3d 560 (2d Cir.
…17 CERTIFICATE OF SERVICE ..................................................................................................... 19 i TABLE OF AUTHORITIES …
…period is highly relevant to the sexual abuse allegations. For example, the flight logs demonstrate that Maxwell was flying on Jeffrey Epstein’s planes over 360 times from 1999 – 2005. In addition, Maxwell flew with plaintiff when she was a…
…Robert Giuffre. 6 Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 8 of 40 ! N. Paramentata, NSW from approximately 2003 - 2005, but she is not certain of those dates. At this location, Ms…
…were very young, 14 or the middle or the front end? 15 but I cannot say that they were 18 ard old. 15 A. I saw her on January 2005, sir, and I was 16 Q. Right. Let me just…
…1328-41 Filed 01/05/24 Page 4 of 31 Iridium India Telecom Ltd. v. Motorola, Inc., 165 Fed.Appx. 878 (2d Cir.2005)............................................................................................. 23 Jane Doe No. 2 v. Epstein, No. 9:08-cv-80119-cv-KAM (S.D…
…draft statements, concerning Ms. Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address. In response, Defendant stated: “Ms. Maxwell…
…part of Mr. Epstein's employ. I 4 bring that up because we are not talking about a long-term 5 trusted employee that would have any actual information about 6 anything. 7 After 2005, he works for someone else. …
…drive' in Quest Red's new true crime documentary special Who Killed Jeffrey Epstein? Jeffrey Epstein and Ghislaine Maxwell attend de Grisogono Sponsors The 2005 Wall Street Concert Series Benefitting Wall Street Rising on March 15, 2005 in New York …
…228 F.R.D. 111, 113 (D. Conn. 2005). “Whether a subpoena subjects a witness to undue burden within the meaning of [Rule 45(d)(3)(A)(iv)] ‘depends upon such factors as relevance . . . and the burden imposed.’” Garneau v…
…Giuffre, by You, Ross Gow, or any other individual, from 2005 to the present, including the dates of any publications, and if published online, the Uniform Resource Identifier (URL) address. RESPONSE: Ms. Maxwell objects to this Request on the grounds…
…cv-07433-LAP Document 1090-4 Filed 07/30/20 Page 12 of 29 asserting the work-product privilege “bears the heavy burden of establishing its applicability.” In re Grand Jury Subpoena Dated July 6, 2005, 510 F.3d 180…
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