gov.uscourts.nysd.447706.79.1.pdf PDF
…SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 79-1 Filed 04/04/16 Page 3 of 12 2 G3o5giuA phone conference 1 (Case called) 2 THE DEPU…
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gov.uscourts.nysd.447706.82.0_2.pdf PDF
…SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 Case 1:15-cv-07433-LAP Document 82 Filed 04/07/16 Page 2 of 11 2 G3o5giuA phone conference 1 (Case called) 2 THE DEPUTY CLERK: Counsel, can you please…
gov.uscourts.nysd.447706.59.0.pdf PDF
…of privileged and potentially privileged documents. For example, Defendant’s Request No. 20 calls for the production of “[a]ny Document reflecting Your intent, plan or consideration of, asserting or threatening a claim or filing a lawsuit against another Person…
gov.uscourts.nysd.447706.1256.25.pdf PDF
…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…
gov.uscourts.nysd.447706.1327.12.pdf PDF
…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…
gov.uscourts.nysd.447706.1200.8_1.pdf PDF
…Jeff and I talked about the scheduling of depositions and trial, and during that call Jeff said he received the search terms and thought the search terms were overbroad. I told him I had not seen them and that Meredith…
gov.uscourts.nysd.447706.1202.1_1.pdf PDF
…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…
gov.uscourts.nysd.447706.1198.29_1.pdf PDF
…LAP Document 1198-29 Filed 01/27/21 Page 3 of 16 Ms. Giuffre objects to the requests to the extent Defendant’s Discovery Requests call for the production of documents or information that is already in the possession, custody…
gov.uscourts.nysd.447706.320.0.pdf PDF
…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…
gov.uscourts.nysd.447706.1256.8.pdf PDF
…job was for Epstein.8 That other young females were similarly recruited by the Defendant is evidence that Ms. Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant defamed her when calling her a liar…
gov.uscourts.nysd.447706.110.0.pdf PDF
…LAP Document 110 Filed 04/21/16 Page 5 of 7 . . does not call for certification that the discovery response is ‘complete,’ but rather incorporates the Rule 26(b)(2)(C) proportionality principle.”); Kiobel v. Royal Dutch Petroleum Co., No…
gov.uscourts.nysd.447706.229.6.pdf PDF
…available the week of the 27th. I told him I would call him to coordinate a new date once I had spoken with you. I have not heard from anyone representing Dana Burns yet. I was hoping you could tell…
gov.uscourts.nysd.447706.1325.7.pdf PDF
…women to recruit minors to have sex with him. 4 Most recently, a witness testified that Defendant would call him and ask him to bring over young girls that she would provide to Epstein. See McCawley Decl. at Exhibit 9…
gov.uscourts.nysd.447706.1202.0_2.pdf PDF
…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…
gov.uscourts.nysd.447706.288.1.pdf PDF
…Jeff and I talked about the scheduling of depositions and trial, and during that call Jeff said he received the search terms and thought the search terms were overbroad. I told him I had not seen them and that Meredith…
gov.uscourts.nysd.447706.1325.14.pdf PDF
…Epstein used other women to recruit minors to have sex with him.5 Most recently, a witness testified that Defendant would call him and ask him to bring over young girls that she would provide to Epstein. See McCawley Decl…
gov.uscourts.nysd.447706.199.0.pdf PDF
…Gow, for a deposition, but Defendant has refused. Defendant has refused this request despite acknowledging that Defendant plans to call Mr. Gow for testimony at trial. Ms. Giuffre may now be forced to have to go through the Hague Convention…
gov.uscourts.nysd.447706.1330.17.pdf PDF
…words that were put in that statement? MR. PAGLIUCA: I'm going to object and instruct you to the extent this calls for any privileged communications between yourself and Mr. Barden or another lawyer representing you, we're asserting privilege…
gov.uscourts.nysd.447706.1256.11.pdf PDF
…job was for Epstein.7 That other young females were similarly recruited by the Defendant is evidence that Ms. Giuffre is telling the truth about her experiences – and thus direct evidence that Defendant defamed her when calling her a liar…
gov.uscourts.nysd.447706.1200.1.pdf PDF
…claim. Specifically, Ms. Giuffre has accused Defendant of defaming her by calling her a liar when Ms. Giuffre came forward with accusations of Defendant’s involvement in her abuse. As truth is a defense to defamation under New York law…