…7433-LAP Dear Judge Preska, Plaintiff writes in response to Defendant’s letter dated September 30, 2020, seeking clarification from the Court regarding Doe 1 and Doe 2’s communication to the Court. ECF No. 1123. As a preliminary matter…
…RANSOME REFUSED TO PRODUCE RELEVANT, RESPONSIVE DOCUMENTS WITHOUT BASIS .................................................................................................................. 3 A. Requests 1, 4, 5, 14: Communications with Witnesses Related to this Case ...................... 3 B. Request 2: Fee Agreements .…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S REPLY MOTION TO COMPEL ALL WORK PRODUCT AND ATTORNEY CLIENT COMMUNICATIONS WITH PHI…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S REPLY MOTION TO COMPEL ALL WORK PRODUCT AND ATTORNEY CLIENT COMMUNICATIONS WITH PHI…
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S REPLY IN SUPPORT OF MOTION TO COMPEL ALL WORK PRODUCT AND ATTORNEY-CLIENT COMMUNICATIONS WITH PHILIP BA…
…and Steven A. Williams in support of Plaintiff’s Briefing on an Adverse Inference Instruction Regarding Defendant’s Failure to Comply with This Court’s Orders to Produce Her Electronic Documents and Communications (DE 838) filed on April 7, 2017.…
…RANSOME REFUSED TO PRODUCE RELEVANT, RESPONSIVE DOCUMENTS WITHOUT BASIS .................................................................................................................. 3 A. Requests 1, 4, 5, 14: Communications with Witnesses Related to this Case ...................... 3 B. Request 2: Fee Agreements .…
…you are hereby notified that Bny dissemination, distribution, copying or other use of this communication is strictly prohiqlted and no priVilege is waived. If you have received this communication in error, please immediately notify' the sender by replying to-this…
…Washington, D.C. 20005 Telephone: (202) 583-2500 Fax: (202) 583-0565 Mobile: (202) 595-4466 Web Site: www.gpoelaw.com This communication is intended solely for the use of the addressee. It may contain information that is privileged, confidential…
…the requests as 3 Case 1:15-cv-07433-LAP Document 1330-2 Filed 01/05/24 Page 5 of 40 overly burdensome to the extent that they would require logging voluminous and ever-increasing privileged communications between Ms…
…P. Specifically, Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing privileged communications between Ms. Giuffre and her counsel after the date litigation commenced on September 21, 2015…
…In terms of preparing for this deposition, what documents did you review?” Ms. Maxwell was instructed to not answer the question as it related to privileged communications between Ms. Maxwell and counsel. Ms. Maxwell was asked if any of the…
…17 MR. PAGLIUCA: Thank you for 18 that speaking objection, Ms. 19 McCawley, and communicating that 20 information to the witness, which 21 you know is totally improper. 22 MS. MCCAWLEY: Now, that's 23 two people objecting right now…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…li 2 Q. Okay . Ever since this communication that 2 t ime I went to the deposition I was in Palm 3 Ms. Maxwell made to you where she called you 3 Beach and I did my duty, I mean…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…P. Specifically, Ms. Giuffre objects to the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing privileged communications between Ms. Giuffre and her counsel after the date litigation commenced on September 21, 2015…
…witness Ms. Ransome has provided more significant evidence, including photographic evidence and electronic communications, than Defendant has produced in the two years she has been litigating this matter. Defendant has not produced a single document prior to 2009 and not…
…the requests as overly burdensome to the extent that they would require logging voluminous and ever-increasing 3 Case 1:15-cv-07433-RWS Document 71-2 Filed 03/23/16 Page 5 of 45 privileged communications between Ms…
…In terms of preparing for this deposition, what documents did you review?” Ms. Maxwell was instructed to not answer the question as it related to privileged communications between Ms. Maxwell and counsel. Ms. Maxwell was asked if any of the…
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