…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…
…1 A. Plaintiff’s Response is Misleading, At Best .............................................................. 1 B. Plaintiff’s Responses and Log Fail to Reveal Whether Privilege Claimed as to Any Category of Documents .............................................................................................…
…privilege – Cross-examination – When court could go behind affidavit of documents – Third party sought specific disclosure of documents – Litigation privilege claimed – Material sought gathered in course C of investigations into incident – Dominant purpose of investigations so that solicitors could provide…
…the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship to any press statements or alleged defamation and providing alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense that Plaintiff would want…
…Maxwell could not testify were based either on a lack of any personal knowledge or the fact that the events claimed by Plaintiff did not actually happen. 1 Case 1:15-cv-07433-LAP Document 1090-18 Filed 07…
…The two lawyers alleged that Dershowitz defamed them when he claimed that they knowingly filed a lawsuit containing falsehoods about him or at least failed to properly investigate their client’s allegations that Dershowitz had sexual relations with her when…
…kitten' who enjoyed her lavish lifestyle, former friends have claimed. Virginia Roberts is currently in the midst of a lawsuit claiming she was recruited to join Epstein's harem of underage women in 1999, naming Prince Andrew and attorney Alan…
…disgraced tycoon Robert Maxwell; Epstein ‘wasn’t beyond killing someone’ to keep his sex addiction alive, the witness claimed. Annie Farmer, now 40, helped keep Epstein behind bars last July after giving evidence about her ordeal as a teenager during…
…Is it the three 23 sentence fragments contained in paragraph 30 against Ghislaine 24 Maxwell are untrue, shown to be untrue, claimed or obvious 25 lies, or does it include some additional or extra false SOUTHERN DISTRICT REPORTERS, P.C. …
…issue . Is it the three 23 sentence fragments contained in paragraph 30 against Ghislaine 24 Maxwell are untrue, shown to be untrue, claimed or obvious 25 lies, or does it include some additional or extra false SOUTHERN DISTRICT REPORTERS, P …
…26, 2016,,. Plaintif f fi led the ins tant motio n to compel Defendant to respond to interrogatories to which Defendant has claimed the protection of the attorney-client, attorney -cl ie nt-ag ent , and common interest privileges. Oral…
…Maxwell could not testify were based either on a lack of any personal knowledge or the fact that the events claimed by Plaintiff did not actually happen. 1 Case 1:15-cv-07433-LAP Document 1320-20 Filed 01…
…Maxwell could not testify were based either on a lack of any personal knowledge or the fact that the events claimed by Plaintiff did not actually happen. 1 Case 1:15-cv-07433-LAP Document 1320-20 Filed 01…
…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…
…Maxwell could not testify were based either on a lack of any personal knowledge or the fact that the events claimed by Plaintiff did not actually happen. 1 Case 1:15-cv-07433-LAP Document 189 Filed 06/06…
…Plaintiff has been attempting to dodge the production of these documents for months. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” did not exist, Plaintiff threw…
…the police reports demonstrate Plaintiff’s tumultuous home life, bearing no relationship to any press statements or alleged defamation and providing alternative causation to any of Plaintiff’s now-claimed emotional distress. It makes perfect sense that Plaintiff would want…
…Reply at 3, n.4). In fact, Detective Recarey testified that none of the underage girls interviewed in connection with his investigation into Epstein claimed to have been hired by Maxwell; in fact, none of them mentioned Ms. Maxwell at…
…and $400 for a subsequent alleged sex session at Epstein’s NYC mansion. A third encounter, she claimed, happened on Epstein’s tropical orgy island, where the two had sex with “approximately eight other girls,” according to the af뒫…
…cross examination, not one. Any standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein…
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