…last July after giving evidence about her ordeal as a teenager during a bail hearing. The financier was found dead in his cell the following month. Ms Farmer is now suing Epstein’s estate and Maxwell in the New York…
…Id. at 75. Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that she could be on call regularly. Id. at 77. Whether Defendant was required to be on call to come to…
…Id. at 75. ! Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that she could be on call regularly. Id. at 77. ! Whether Defendant was required to be on call to come to Epstein’s…
…Defendant then argues that Ms. Ransome should therefore be punished by having to make burdensome and invasive disclosures of such things as her boyfriend’s cell phone number and information from her current bank account. Unwilling to confine her attacks…
…Id. at 75. • Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that she could be on call regularly. Id. at 77. • Whether Defendant was required to be on call to come to Epstein's…
…we want more documents, we want things like 2 paycheck records. She testified she doesn't have them. 3 We want her boyfriend's cell phone number. Why do 4 they want her boyfriend's cell phone number? She is…
…any related entity from 1999 – present. DOCUMENT REQUEST NO. 21 All telephone records associated with you, including cell phone records from 1999 – present. DOCUMENT REQUEST NO. 22 All documents relating to calendars, schedules or appointments for you from 1999 – present. …
…this dubious premise, Defendant then argues that Ms. Ransome should therefore be punished by having to make burdensome and invasive disclosures of such things as her boyfriend's cell phone number and ;njonnation from her current bank account. Unwilling to…
…Id. at 75. ! Whether Defendant could recall telling Ms. Giuffre that she needed a cell phone so that she could be on call regularly. Id. at 77. ! Whether Defendant was required to be on call to come to Epstein’s…
…privileged is proper. 10 10. Request No. 21: All telephone records associated with you including cell phone records from 1999 – present. Request No. 22: All documents relating to calendars, schedules or appointments for you fr…
… Under New York law, defamation per se as alleged in this case presumes damages and special damages do not need to be plead and proven. See Celle v. Filipino Reporter Enterprises Inc., 209 F.3d 163, 179 (2 nd Cir…
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