giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.27
5 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…I shall not
distinguish between those two companies for the purposes of this judgment (because it is
not necessary to do so) and shall treat all relevant copyright and confidentiality rights as
being vested in what I will call "USP"…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.8
12 pg
…Ms. Giuffre has also alleged that Epstein and the
Defendant were aided by others who played keys roles in the sex trafficking organization,
including Sarah Kellen and Nadia Marcinkova. Defendant has called Ms. Giuffre a “liar” and
Ms. Giuffre is…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.19
15 pg
…in that statement?
7 MR. PAGLIUCA: I'm going to object
8 and instruct you to the extent this
9 calls for any privileged communications
10 between yourself and Mr. Barden or
11 another lawyer representing you, we're
12…
giuffre-maxwell
1320-8
12 pg
…Ms. Giuffre has also alleged that Epstein and the
Defendant were aided by others who played keys roles in the sex trafficking organization,
including Sarah Kellen and Nadia Marcinkova. Defendant has called Ms. Giuffre a “liar” and
Ms. Giuffre is…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…Ms. Giuffre has also alleged that Epstein and the
Defendant were aided by others who played keys roles in the sex trafficking organization,
including Sarah Kellen and Nadia Marcinkova. Defendant has called Ms. Giuffre a “liar” and
Ms. Giuffre is…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…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?
…
giuffre-maxwell
gov.uscourts.nysd.447706.753.1
7 pg
…18 THE COURT: By the way, that was not stated with
19 respect to the financial information dispute. Let's call it
20 that. This is the first time I hear this.
21 MR. CASSELL: I can't recall whether…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…deposition testimony” and said that “[a]ll such motions, at least on their face, call upon the court
to exercise its Article III powers.”
Ms. Maxwell and J. Doe’s repeated assertion that these documents are entitled to only a…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.14_1
11 pg
…even saying
22 Virginia is a liar has hazards.
23 You knew at the time you called
24 Virginia a liar in early January of 2015 that
25 that was something that would result in a
Page 405
1…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…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 omission of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…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 omission of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.17
25 pg
…the present, on the grounds that it is overly broad and
unduly burdensome and calls for the production of documents that are irrelevant to this action
and not reasonably calculated to lead to the discovery of admissible evidence. The Complaint…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…for
the subpoenaing party.
2. This Request calls for the production of all responsive Documents in your possession,
custody or control without regard to the physical location of such documents.
3. If any Document was in your possession or control…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…the obligations imposed by the Federal Rules of Civil
Procedure.
6. Ransome objects to the Definitions and Instructions and to each Request to the
extent that it calls for the production of documents that are not in her custody, possession…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…the obligations imposed by the Federal Rules of Civil
Procedure.
6. Ransome objects to the Definitions and Instructions and to each Request to the
extent that it calls for the production of documents that are not in her custody, possession…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…brief, Ms. Giuffre alleges that defendant Ms. Ghislaine Maxwell
defamed her by calling her a "liar" for filing documents alleging that Maxwell and her boyfriend,
Jeffrey Epstein, had sexually abused her and trafficked her for sexual purposes. See Mccawley
Deel.…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…the obligations imposed by the Federal Rules of Civil
Procedure.
6. Ransome objects to the Definitions and Instructions and to each Request to the
extent that it calls for the production of documents that are not in her custody, possession…