…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL …
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REPLY IN SUPPORT OF MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL …
…EPSTEIN Plaintiff Virginia Giuffre, by and through her undersigned counsel, hereby files this response to Jeffrey Epstein’s motion to quash a subpoena calling for his testimony. Having spent months attempting to avoid service of a subpoena, Epstein claims that…
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S REPLY IN SUPPORT OF MOTION IN LIMINE TO PRECLUDE DEFENDANT FROM CALLING PLAINTIFF’S ATTORNEYS AS WITNESSES AT TRIAL I…
…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? …
…Maxwell, who is 20 appearing by telephone. 21 SARAH RANSOME, having been 22 called as a witness, having first 23 been duly sworn by a Notary 24 Public (Jeremy Richman) of the 25 State of New York, was examined …
… 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…
… 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…
…East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms . See the property receipt for…
…should not have to answer other of the subpoena requests nor answer deposition questions which are designed to lead to admissible evidence and which, concededly, do not call for privileged answers. The Opposition, long on screenshots of photos and documents…
…East side of the house. In the Northeast bedroom closet I found adult sex toys called Twin Torpedoes. Soap made in the shape of a penis and vagina were also found in these upstair bedrooms . See the property receipt for…
…should not have to answer other of the subpoena requests nor answer deposition questions which are designed to lead to admissible evidence and which, concededly, do not call for privileged answers. The Opposition, long on screenshots of photos and documents…
…the house, I 6 never saw something like that. 7 Q. Do you know if Virginia was 8 required to be on call at all times to come 9 to the house if Jeffrey wanted her there? 10 MR. PAGLIUCA…
…Time are Proper where Service through the Hague Requires a Foreign Judicial Order Courts routinely grant extensions of time of deadlines when awaiting Hague Convention service, and the facts and circumstances in this case call for the same. Daly v…
…18; 96:8-15. “Q. …when Ghislaine Maxwell would call you during the time you were living with Virginia, she would ask you what specifically? A. Just if I had found any other girls just to bring to Jeffrey…
… 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…
…very next page, when discussing the information gleaned from those police reports that Mr. Pagliuca had prior to the conferral call, Defendant claims the information from the police reports is “irrelevant,” stating: “The records requested are irrelevant. Plaintiff has asserted…
…Case 1:15-cv-07433-LAP Document 1328-17 Filed 01/05/24 Page 3 of 6 Page 166 Page 168 1 written down anywhere? 1 for now we'll call it a massage -- as well as 2 A. No…