…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S REDACTED BRIEF IN SUPPORT OF THE PRIVILEGE CLAIMED FOR HER IN CAMERA SUBMISSION Plaintiff Virginia L. Giuffre, by…
…Page 09/21/15 Page56 ofof 1213 21. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that consequently…
…09/21/15 Page 5 of 12 21. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that consequently she was leaving the United States for London with no plans of ever returning. In fact, however…
…15 12/17/15 Page Page5 6ofof1213 21. To avoid her deposition, Maxwell claimed that her mother fell deathly ill and that consequently she was leaving the United States for London with no plans of ever retu…
…5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons, attaching an abbreviated privilege log. 8. While these discovery issues were pending, in the…
…5), while simultaneously submitting 14,825 pages of relevant materials under seal to the Court. The Government claimed that these pages were “privileged” for various reasons, attaching an abbreviated privilege log. 8. While these discovery issues were pending, in the…
…evidentiary hearing might be required, as contemplated under the Protocol. At this point, the foregoing serves only to further illustrate that the non-parties are not the source of the claimed delay or inefficiencies. Rather, any execution issues are directly…
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