…and states as follows: STATEMENT OF CONFERRAL The undersigned has conferred with counsel for Plaintiff, who stated that they do not agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition. INTRODUCTION Plaintiff has deposed…
…evidence whatsoever that Ms. Giuffre was the child victim of any sexual abuse. As she testified at her deposition: 2 Q. Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts? A. No. Q…
…to two hours.” Sealed Transcript, Nov. 10, 2016, at 34. DISCUSSION Defendant now moves for appointment of a special master, offering two arguments. First, Defendant claims that she is concerned about “repetitive duplicative questioning” of certain subjects. Mot. at 2…
…Excerpts from July 22, 2016, Deposition of Ghislaine Maxwell at 174:2-4. an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females…
…photographs, notes, letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers, journals, diaries, calendars, appointment books, papers, agreements, contracts, invoices, analyses, transcripts, plaques, correspondence, telegrams, drafts, data processing or computer diskettes and CD disks, t…
…Excerpts from July 22, 2016, Deposition of Ghislaine Maxwell at 174:2-4. an 11:00 appointment. There were other individuals that had called during that day. Q. And when you would -- when you would see females…
…1 - CONFIDENTIAL 2 know the ex t ent of their relat ions hip . But she 3 would schedule his appointments and handle clerical 4 th ings for him as far as I can see. 5 Q. All right . 6 And…
…testified at her deposition: 2 Case 1:15-cv-07433-LAP Document 1328-35 Filed 01/05/24 Page 4 of 10 Q. Do you know what happened during the massage appointments with Jeffrey - Epstein and Virginia Roberts? A…
…Plaintiff’s Request No. 22 asks for “All documents relating to calendars, schedules or appointments for you from 1999 – present.” The overbreadth of this request is obvious. And while this Request may technically yield relevant documents, the Request could also…
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