…Opposition to Defendant’s Motion To Reopen Plaintiff’s Deposition. 2. Attached as Exhibit D (filed under seal) is a true and correct copy of correspondence between Plaintiff and literary agent Marianne Strong dated February 19, 2014 and February 21…
…R. Civ. P. 37(a)(3), files this Renewed Motion to Compel Settlement Agreement regarding the confidential settlement agreement between Plaintiff and Jeffery Epstein, and states as follows: INTRODUCTION As part of her scorched earth litigation practice, Plaintiff, without any…
…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…
…15 Civ. 7433 (LAP) Dear Judge Preska: Pursuant to the Court Order dated April 19, 2022, Ms. Maxwell hereby files those documents ordered unsealed between the Dkt. Nos. 321-6 and 631, with the exception of Dkt. Nos. 173-5…
…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…
…action. I respectfully submit this declaration in support of Defendant’s Opposition to Plaintiff’s Motion for Forensic Examination. 2. Attached as Exhibit A are true and correct copies of correspondence between counsel for Ms. Maxwell and counsel for Ms…
…Ghislaine is putting the word out to her wealthy friends that she is ready to sell,” and wants more than $20 million. Ghislaine Maxwell on the Upper East Side Perhaps she hopes to put some distance between herself and Epstein…
…and for Confidential Access to Judicial Records and Discovery Documents (“Motion”) and states as follows: INTRODUCTION The Government seeks to intervene in this five-year old, closed civil defamation action between two private civil litigants, Plaintiff Giuffre and Defendant Ms…
…denial comes after two Sunday papers in Britain published interviews with the woman in which she claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three times between 1999 and 2002…
…Epstein and Virginia Roberts? A. No. Q. Were you ever present to view a massage between Jeffrey Epstein and Virginia Roberts? A. I don't recollect ever seeing Virginia and Jeffrey in a massage situation. Q. Do you ever recollect…
…of course, to immediately implement the destruction provisions in that order. But counsel are now torn between two courts. Three appeals are currently pending in the Second Circuit regarding the protective order, and appellants in several of the appeals have…
…WC2A 2LL Date: 1 March 2004 Before : THE HONOURABLE MR JUSTICE MANN --------------------- Between : …
…2016. 3. Attached as Exhibit B (filed under seal) are true and correct copies of conferral communication between counsel, including a true and correct copy of Jeffrey Epstein’s written waiver of claims concerning settlement agreement’s confidentiality provision dated…
… 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…
…deposition of Sarah Ransome on February 17, 2017, designated Confidential under the Protective Order. 4. Attached as as Exhibit C (filed under seal) is a true and correct copy of the engagement letter between Ms. Ransome and Farmer, Jaffe, Weissing…
…CONFIDENTIAL 2 as part of this case, right? 3 A. Correct, because it was between two 4 consenting adults. 5 Q. Exactly. 6 And so that's Ms. Sjoberg, and then the 7 other individual, I think you said Bolero…
…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…
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