…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…
…21 Page 3 of 10 Case 1:15-cv-07433-LAP Document 1199-22 Filed 01/27/21 Page 4 of 10 Q. Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts? A…
… 3 A No. I -- she would have filled out a new 4 patient packet and showed up for a new patient 5 appointment for a particular reason. I reviewed it. 6 7 Jane Doe 2 8 Q Do you know…
…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, tapes of any nature and computer interpretations thereof…
…affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts,…
… 11 A. I don't ever recall paying her. 12 Q. Do you know what happened during 13 the massage appointments with Jeffrey Epstein 14 and Virginia Roberts? 15 MR. PAGLIUCA: Objection to the 16 form and foundation. 17 A…
…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…
…affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts,…
…affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts,…
…affidavits, statements, sllmmaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer print…
…affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts,…
…affidavits, statements, summaries, opinions, tests, experiments, analysis, evaluations, journals, balance sheets, income statements, statistical records, desk calendars, appointment books, lists, tabulations, sound recordings, data processing input or output, microfilms, checks, statements, receipts, summaries, computer printouts,…
…telephone records associated with you, including cell phone records from 1999 – present.” (No. 21); All documents relating to calendars, schedules or appointments for you from 1999 – present,” (No. 22). See Motion for Stay, Ex. A. Given the strength of…
…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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