…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…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…INTRODUCTION ................................................................................................................. 1 FACTUAL BACKGROUND ................................................................................................. 2 I. PLAINTIFF’S FAILURE TO IDENTIFY THE SPECIFIC QUESTIONS CLAIMED UNANSWERE…
…younger the better. [The girl] once stated she once tried to bring a 23-year- old female and Epstein stated that the female was too old ." According to the women who claimed to have visited his home, they were paid…
…LAP Document 64 Filed 03/22/16 Page 2 of 14 Table of Contents Introduction ......................................................................................................................... 1 Certificate of Conferral ..................................................................…
…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…
…York. The second denial comes after two Sunday papers in Britain published interviews with the woman in which she claimed that she was forced by American financier Jeffrey Epstein to have sex with Prince Andrew at least three times between…
…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…
…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…
…friends, including Prince Andrew. It's claimed she had sex with him three times when she was 17 at Jeffrey Epstein's luxury Caribbean Island home and in New York and London, all denied by Prince Andrew. VICTORIA MURPHY, UK…
…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. …
…Defendant has claimed in her deposition that she did not procure girls for sex with Epstein nor notice the 1 Case 1:15-cv-07433-LAP Document 1201-17 Filed 01/27/21 Page 2 of 12 hundreds of…
…And Go Beyond The Requirements Of Rule 26(a). ....................................................................3 B. The Claimed $102,000 For Future Medical Expenses Is Supported By Proper Calculations And Supporting Documents. ...............................................................…
…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 …
…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…
…which Ms. Maxwell is a target. First, Plaintiff claimed that the documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the…
…p. 89-90; 83-84. While Defendant was working with Epstein during the time period when these underage girls were visiting Jeffrey’s home, Defendant claimed to be at the house maybe once in 2005. Id. at p. 84. Yet…