…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF VIRGINIA GIUFFRE’S BRIEF IN SUPPORT OF THE PRIVILEGE CLAIMED FOR HER IN-CAMERA SU…
…LAP Document 64 Filed 03/22/16 Page 2 of 14 Table of Contents Introduction ......................................................................................................................... 1 Certificate of Conferral ..................................................................…
…For example, Defendant swore under oath that she hardly was around Jeffrey Epstein for more than “maybe an hour or two” in the years after 2003 until she claimed she ultimately left his employment in 2008 or 2009. See Pottinger…
…Order together with her Motion to Compel. 2 In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic, Plaintiff claimed she had “recently” learned of this “new” witness…
…643, 645 (2d Cir.2009) (movant had standing to challenge subpoena to itself and its attorneys because it claimed privilege in the material sought). Here, the Court clearly should grant a protective order barring disclosure of all of Ms. Giuffre…
…her various email accounts, After issuing that Order, Defendant implausibly claimed that However, Accounts Defendant used during the relevant period were excluded from this “search.” Moreover, Defendant has inappropriately refused to disclose what email accounts she has used during the…
…643, 645 (2d Cir.2009) (movant had standing to challenge subpoena to itself and its attorneys because it claimed privilege in the material sought). Here, the Court clearly should grant a protective order barring disclosure of all of Ms. Giuffre…
…Order together with her Motion to Compel. 2 In their letter motion to the Court of January 19 as well as during the hearing of February 2 on this topic, Plaintiff claimed she had “recently” learned of this “new” witness…
…D .N .Y .J an.8 ,1993)(applyingthe N ew Y orkstate physician-patientprivilege,and hold ingthat where plaintiff claimed thatshe su ffered emotionald istress,d efend ants d id nothave “alicense to ru mmage throu ghallaspects of the plaintiff' …
…EarthLink account) and it contains relevant information. Yet Plaintiff claims she 4 Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 20 of 42 Because Plaintiff claimed she cannot access her Microsoft account, Ms…
…Epstein’s. It was not until the Joinder Motion in December 2014 that she claimed she engaged in sexual relations with Mr. Dershowitz, something he adamantly and publicly denied. At the heart of this case is the question of whether…
…EarthLink account) and it contains relevant information. Yet Plaintiff claims she 4 Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 7 of 17 - - Because Plaintiff claimed she cannot ac…
…of her FIT essay but testified that she does not believe she has the application but Jeffrey Epstein or the Defendant likely have a copy because they claimed to be assisting her with the application and submission process for FIT)…
…contrary to the previous claim that it would be enormously burdensome to sort through these “hits,” Defendant now claimed that she had not found any responsive documents. It is possible that Defendant changed her mind over the weekend and reversed…
…stare separately for each Document, i_n addition to any other information requested: (a) t he specific request ·which calls for the production; (b) the nature of the privilege claimed; (c) its date; ( d) the name and address or each…
…1330-22 Filed 01/05/24 Page 9 of 22 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…
…of her FIT essay but testified that she does not believe she has the application but Jeffrey Epstein or the Defendant likely have a copy because they claimed to be assisting her with the application and submission process for FIT)…
…contrary to the previous claim that it would be enormously burdensome to sort through these “hits,” Defendant now claimed that she had not found any responsive documents. It is possible that Defendant changed her mind over the weekend and reversed…
…if he climaxed as he masturbated under the towel . Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion…
…if he climaxed as he masturbated under the towel . Additionally she never looked blow his waist. She claimed that Epstein would convince her to remove her clothes. She eventually removed her clothes and stayed in her thong panties. On occasion…
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