…Ghislaine Maxwell Dear Ms. Menninger: I am in receipt of your letter of April 6, 2016, where you have attempted to memorialize a telephone conversation in which you called me concerning Giuffre v. Maxwell, Case No. 15-cv- 07433-RWS…
…Jeffrey multiple times per day? A. No. As when I was finished another girl was called by Ghislaine (Defendant). And when they had finished another girl was called. Q. How do you know that another girl was called by Ghislaine? …
…first and surnames.1 By correspondence of July 14, Ms. Maxwell’s counsel specifically identified the problematic terms, agreed to a limited list, and requested a substantive conferral call on this issue. See Menninger Decl., Ex. B. In that correspondence…
… No, sir. 5 Q. So when there would be a message from one 6 of them while they were out of town, they would call 7 you, call you on the telephone? 8 A. I haven't spoken to Ghislaine…
…Specifically, I stated “I am available by telephone today and tomorrow to discuss the issues raised herein.” Despite this clear request for a call if there were issues you wished to discuss, or if you had specific RFP’s to…
…that has yielded not so much as a single goose feather. It is time to call off the hunt. Submission Concerning Search Terms The Requests for Production Ms. Maxwell served Responses and Objections to Plaintiff’s First Discovery Requests on…
… No, sir. 5 Q. So when there would be a message from one 6 of them while they were out of town, they would call 7 you, call you on the telephone? 8 A. I haven't spoken to Ghislaine…
…first and surnames.1 By correspondence of July 14, Ms. Maxwell’s counsel specifically identified the problematic terms, agreed to a limited list, and requested a substantive conferral call on this issue. See Menninger Decl., Ex. B. In that correspondence…
… No, sir. 5 Q. So when there would be a message from one 6 of them while they were out of town, they would call 7 you, call you on the telephone? 8 A. I haven't spoken to Ghislaine…
… No, sir. 5 Q. So when there would be a message from one 6 of them while they were out of town, they would call 7 you, call you on the telephone? 8 A. I haven't spoken to Ghislaine…
…that has yielded not so much as a single goose feather. It is time to call off the hunt. Submission Concerning Search Terms The Requests for Production Ms. Maxwell served Responses and Objections to Plaintiff’s First Discovery Requests on…
…cv-07433-LAP Document 441 Filed 09/21/16 Page 5 of 18 1 In ad d ition,cou nselforM s.Giu ffre mad e mu ltiple phone calls to potentialmed icalrecord s cu stod ians in an attemptto locate …
…Epstein household to send and receive messages, a household to which Defendant belonged: Q. So when there would be a message from one of them while they were out of town, they would call you, call you on the telephone? …
…Specifically, I stated “I am available by telephone today and tomorrow to discuss the issues raised herein.” Despite this clear request for a call if there were issues you wished to discuss, or if you had specific RFP’s to…
…” Or that it is not a real injury? COULD NOT HAPPEN TO ME If you hear testimony that someone was damaged because she was called a liar, is there anyone who believes they would judge the Plaintiff by whether…
…Upon a motion to compel, a Court is called upon to evaluate the discovery requests as well as the responses and objections. Local Rule 37.1 is designed to protect against the exact type of self-serving editing of the…