…33. She strenuously argues that she has “disclosed” various treatment providers because their names are buried in records that she has belatedly produced and which she obtained only after defense counsel had identified their existence and absence through independent investigation…
…33. She strenuously argues that she has “disclosed” various treatment providers because their names are buried in records that she has belatedly produced and which she obtained only after defense counsel had identified their existence and absence through independent investigation…
…DE 230 and Related Pleadings Plaintiff’s response regarding DE 230 is largely the same as her response to DE 199 infra, with one significant exception: buried on page 19 of her Response to Ms. Maxwell’s Objection to Unsealing…
…a chance to review either because they were not produced or because they were produced so late in the day buried amidst thousands of pages of meaningless discovery that her attorneys have not had the opportunity to review and to…
…Maxwell is 17 not doing Mr. Epstein's bidding and really could care less 18 about what Mr. Epstein says she should or should not do. 19 What is buried in these papers, your Honor, and is 20 very disingenuous…
…of Plaintiff’s hyperbole and indignation cannot change the simple fact that Plaintiff willfully and intentionally set a bonfire and burned her journal that she admits contained information relevant to test the allegations she made in the Crime Victims Right…
…to join the Crime Victims' Rights I Act litigation ("CVRA Litigation") represented by her current counsel , Plaintiff willfully and deliberately burned her long-ke tjoumal in a bonfire'in her backyard. According to Plaintiff, I the JOUma] contained her tlfoughts…
…was in the process of trying to implead herself into the CVRA case and under a preservation obligation, she and her husband had a bonfire and purposefully burned her journal that she had kept for years containing relevant information. Specifically…
…denied. As part of a therapeutic exercise, Ms. Giuffre burned a personal journal with memories of her sexual abuse in 2013 – two years before the defamation in this case occurred and three years before this litigation began. Sanctions are, accordingly…
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