giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…for
Ms. Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre
and bring her to Epstein’s mansions to be sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to…
giuffre-maxwell
1320-8
12 pg
…for
Ms. Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre
and bring her to Epstein’s mansions to be sexually abused. At several points during her recent
deposition, Ms. Maxwell refused to…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…Giuffre to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre
and bring her to Epstein’s mansions to be sexually abused.
Because of Epstein’s importance to this case, Ms. Giuffre has diligently tried…
giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…and vice versa.
b) “And” as well as “or” shall be construed either disjunctively or
conjunctively as necessary to bring within the scope hereof any
information (as defined herein) which might otherwise be construed to be
outside the scope of…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…to any information that would be admissible at
trial. The information is being sought solely for the purposes of harassment and embarrassment
of this witness.
The requests are also grossly overbroad, seeking to probe literally every financial matter
in Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…to any information that would be admissible at
trial. The information is being sought solely for the purposes of harassment and embarrassment
of this witness.
The requests are also grossly overbroad, seeking to probe literally every financial matter
in Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…with respect to the practice
which has been alleged and the duties alleged to be performed by Defendant, ‘activities’ being
defined as sexual abuse or trafficking of any female,” in which case her answers reflect the
period 2000-today. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…Blatchford, the Administrator of Ms. Giuffre’s Estate, has been
substituted for Ms. Giuffre in the Second Circuit prior to this case being remanded to this Court.
See Order Granting Motion for Substitution, Giuffre v. Maxwell, 24-182 (2d Cir.)…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…relevant to
the underlying action. Ransome objects to Defendant being permitted to utilize the underlying
action to obtain backdoor discovery into a separate action entirely unrelated to whether or not
Maxwell defamed Virginia Roberts Giuffre. Ransome further objects to this…
giuffre-maxwell
1320-17
25 pg
…with respect to the practice
which has been alleged and the duties alleged to be performed by Defendant, ‘activities’ being
defined as sexual abuse or trafficking of any female,” in which case her answers reflect the
period 2000-today. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…7
39
H39YGIUC
1 fearful -- as you know, we have alleged in our papers that this
2 money is being moved offshore so that it will not be reachable
3 in the event that Ms. Giuffre --
4 THE COURT: This…
giuffre-maxwell
gov.uscourts.nysd.447706.371.2
18 pg
…with respect to the practice
which has been alleged and the duties alleged to be performed by Defendant, ‘activities’ being
defined as sexual abuse or trafficking of any female,” in which case her answers reflect the
period 2000-today. Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…that “many documents
attached to the case management pleadings are ‘redundant, immaterial, impertinent, [and/] or
scandalous.” These allegations are untimely, as they are being made years after the underlying
documents were filed with the Court. See Fed. R. Civ. P…
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