…R. Civ. P., and states as follows. I. BACKGROUND After receiving written briefs on the Plaintiff’s Motion for Forensic Examination (DE 96), and hearing oral argument on the same on May 12, 2016, this Court on June 20, 2016…
…for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and …
…for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and …
…for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by her most basic and fundamental discovery obligations. A summary of this ongoing and …
…Party Notices on all remaining Non-Parties, as well as to Does 1 and 2 at newly obtained addresses, and after conferral with Plaintiff’s counsel, undersigned counsel agreed to serve Non-Party Notices to J. Doe 1 through J…
…INTRODUCTION .......................................................................................................................... 1 ARGUMENT .................................................................................................................................. 1 I. PLAINTIFF’S PRODUCTION OF KEY DOCUMENTS AFTER H…
…as it applies to Doe 1 and Doe 2’s recent communication and the related deadlines for objecting and responding. After conferral with Plaintiff’s counsel, the parties were unable to reach an agreement. Depending on the Court’s clarification…
…the State of Massachusetts. 2. I have provided legal representation to Jeffrey Epstein as to specific past and ongoing legal matters both before and after April 2015. I regularly communicated with Mr. Epstein regarding my legal representation of him via…
…attorney at law duly licensed in the State of Massachusetts. 2. I have provided legal representation to as to specific past and ongoing legal matters both before and after April 2015. I regularly communicated with regarding my legal representation of …
…either be able to inform you that I can or instead that I am not authorized to accept service notlater than 5-31 i.e. the day after the Memorial Day weekend. Marty -----Origmal Message---- From: Martin Weinberg Sent: Monday…
…R. Civ. P., and states as follows. I. BACKGROUND After receiving written briefs on the Plaintiff’s Motion for Forensic Examination (DE 96), and hearing oral argument on the same on May 12, 2016, this Court on June 20, 2016…
…an answer today? I have several time sensitive conflicts and then afternoon court commitments Sent from my iPhone 1 Case 1:15-cv-07433-RWS Document 223-2 Filed 06/16/16 Page 3 of 7 On Apr 6, 2016…
…the Protocol suggest that the 7-day clock is not yet running. As Ms. Maxwell points out, the Protocol contemplates specifically that a non-party has 14 days to object to unsealing after service of the relevant excerpts, (dkt. no…
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his employment in 2008 or 2009. See Pottinger…
…of names to “make some effort to match them to actual people who have some relationship to this case (like first name /3 last name or some parts thereof)”). After explaining the appropriate and well-reasoned objections to certain terms…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…have already suffered such a terrible and painful loss over the last few days that I can't even see what life after press he'll even looks like - statements that don't address all just lead to more questions .…
…have already suffered such a terrible and painful loss over the last few days that I can't even see what life after press he'll even looks like - statements that don't address all just lead to more questions .…
…of names to “make some effort to match them to actual people who have some relationship to this case (like first name /3 last name or some parts thereof)”). After explaining the appropriate and well-reasoned objections to certain terms…
…aware, Ms. Giuffre has alleged that Defendant defamed her when she called her a liar after Ms. Giuffre spoke out about being a child victim of sex abuse at the hands of Defendant and Defendant’s long-time boyfriend, convicted…