…of 4 ROSS NEIL· SUTHERLAND GOW - 11/18/2016 · ·1· · · · · · · · ·IN THE HIGH COURT OF JUSTICE · · · · · · · · · · · QUEEN'S BENCH DIVISION ·2 ·3· · · · · · · · · · ·Claim No. CR 2016-624 ·4· ·BETWEEN: ·5· · · · · · · · · · · VIRGINIA L. GIUFFRE · · · · · · · · · · · · · · · · · · · · · …
…DISMISSAL Plaintiff, VIRGINIA GIUFFRE, and Defendant, GHISLAINE MAXWELL, by and through their undersigned counsel, hereby stipulate and agree that pursuant to the Settlement Agreement entered into between the parties and Fed. R. Civ. P. 4l(a)(l)(A)(ii), this…
…DISMISSAL Plaintiff, VIRGINIA GIUFFRE, and Defendant, GHISLAINE MAXWELL, by and through their undersigned counsel, hereby stipulate and agree that pursuant to the Settlement Agreement entered into between the parties and Fed. R. Civ. P. 41(a)(1)(A)(ii), this…
… [email protected] Subject: Fw: SERVICE· Epstein Deposition Ms Schultz, just wanting to be sure there are no email issues between Sigrid and myself. Below is an email sent to Sigrid shortly after noon today. Martin Weinberg From: Martin Weinberg…
… Ex. A (correspondence between Chambers and Plaintiff’s counsel stating: “I just want to make sure that there is nothing MISSING from the Binder that the Judge needs to rule on”). The Court’s review of these materials makes clear…
…2016 deposition of Ghislaine Maxwell, designated Confidential under the Protective Order. 3. Attached as Exhibit B (filed under seal) are true and correct copies of communication between Mr. Gow and Ms. Maxwell Bates stamped GM_01036-01044. Case 1…
…is ordered to collect all ESI by imaging her computers and collecting all email and text messages on any devices in Defendant’s possession or to which she has access that Defendant used between the period of 2002 to present…
…21 GHISLAINE MAXWELL, via teleconference 22 23 24 25 Highly Confidential Page 5 1 HIGHLY CONFIDENTIAL AEO 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the respective 4 parties herein, that filing and…
…07433-LAP Document 1335-7 Filed 01/09/24 Page 6 of 469 Highly Confidential Page 5 1 HIGHLY CONFIDENTIAL AEO 2 IT IS HEREBY STIPULATED AND AGREED 3 by and between the attorneys for the resp…
…What is MindSpring? 17 A. It was a server. I think it was -- the 18 office would have, like, a message system between 19 him, the houses, the employees, his friends. They 20 would write a message on the computer. …
…20, 23, 24, 30); x documents relating to any contact between Ms. Maxwell and law enforcement (RFP 13 and 38); x photos of females under the age of 18 (RFP 7), of any time inside a home or aircraft of…
…included within your Rule 26 disclosures. However, you never submitted a RFP seeking all - communications between our client and your witnesses. There are some RFPs which identify individual witnesses whose communications with our client y…
…What is MindSpring? 17 A. It was a server. I think it was -- the 18 office would have, like, a message system between 19 him, the houses, the employees, his friends. They 20 would write a message on the computer. …
…of 9 produced documents at issue in this pending motion is an email chain showing Epstein’s involvement in crafting yet another draft statement. The other late produced document is a communication between Defendant and her press agent, Ross Gow…
…include all documents of any nature that have been archived or placed in permanent or temporary storage including electronic storage. 5. “Communication” means any transmission or exchange of information between two or more persons, orally or in writing or otherwise…
…What is MindSpring? 17 A. It was a server. I think it was -- the 18 office would have, like, a message system between 19 him, the houses, the employees, his friends. They 20 would write a message on the computer. …
…What is MindSpring? 17 A. It was a server. I think it was -- the 18 office would have, like, a message system between 19 him, the houses, the employees, his friends. They 20 would write a message on the computer. …
…will add to our log. We also located a number of privileged communications between our client and myself following the onset of litigation in this case which will not be logged consistent with both parties' agreed to practice. As predicted…
…Case No. 16-1038. 7. Counsel for Ms. Maxwell also has other various court appearances scheduled between April 13 and April 19, 2016. 8. Counsel for Ms. Maxwell respectfully requests that the hearing on Mr. Cassell’s motion to appear…
…that if it is necessary. 10 What I would ask -- fortunately because we have a 11 sexual differentiation between counsel it won't be necessary 12 for you to identify yourself as we speak and talk. 13 I take it…
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