…several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these late produced communications. I. INTRODUCTION As the Court is well aware, Ms. Giuffre has…
… : : Defendant. : : ----------------------------------------------------------x MEMORANDUM OF LAW IN SUPPORT OF PROPOSED INTERVENOR TGP …
…Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF MEREDITH SCHULTZ IN SUPPORT OF PLAINTIFF’S BRIEFING REGARDING DEFENANT’S FAILURE TO COMPLY WITH THIS COURT’S ORDER TO PRODUCE HER ELECTRONIC DOCUMENTS AND …
…several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these late produced communications. I. INTRODUCTION As the Court is well aware, Ms. Giuffre has…
…01/08/24 Page 3 of 42 Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account…
…07/15/21 Page 2 of 12 Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account…
…nor produce documents from it. Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account to…
…certain accounts. For example, Ms. Giuffre’s first Request sought “[a]ll documents relating to communications with Jeffrey Epstein from 1999 – present.” More important, however, it was this Court’s own Order that required Defendant to search for, and produce…
…the Total defendants’ claim for privilege could not be rejected on the D ground that the Total accident investigation reports and communications were produced pursuant to Total’s regulatory duties under the COMAH Regulations: while there might be an implied…
…nor produce documents from it. Importantly, Defendant has never denied using an email account for communication from 1999-2009, and the facts and circumstances show that it is exceedingly unlikely that Defendant did not use an email account to…
…Epstein and Mr. Dershowitz (RFPs 6, 7, 9 and 10) and communications with Mr. Dershowitz’s counsel (RFP 11); “all documents concerning Virginia Giuffre” (RFP 12); any contracts with or agreement for legal fees to be paid by…
…Ms. Giuffre - defeats such a defense. A reasonable trier of fact could, and should, find that Defendant’s refusal to produce these documents (which include her email communications), support Ms. Giuffre’s claim of defamation. Ms. Giuffre has suffered prejudice…
…given the media attention focused on this case, and Plaintiff’s apparent willingness to publicly disclose confidential information, not to mention Plaintiff’s counsels’ undisclosed communications with the media, Ms. Maxwell rightfully remains skeptical of Plaintiff’s ability to abide…
…Obviously, Ms. Giuffre has a compelling need to obtain Defendant’s documents about her, and she has accordingly requested Defendant’s communications concerning her. Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has…
…This late production occurred despite the fact that Defendant requested all documents relating to communications with or investigations by law enforcement, which Plaintiff claimed she had produced.4 Plaintiff’s pattern of discovery abuses and failure to disclose necessary and…
…Obviously, Ms. Giuffre has a compelling need to obtain Defendant’s documents about her, and she has accordingly requested Defendant’s communications concerning her. Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has…
…a reasonable, good-faith syntax to capture communications with those individuals -- for example: “Alex* w/50 Hall.” Sometimes that takes some trial-and-error – I’m happy to be of any assistance with regard to that process. Please let me…
…Obviously, Ms. Giuffre has a compelling need to obtain Defendant’s documents about her, and she has accordingly requested Defendant’s communications concerning her. Defendant’s documents concerning Ms. Giuffre are directly relevant to this action, particularly because Defendant has…
…the Court’s rulings on Ms. Giuffre’s Motion to Compel for Improper Claim of Privilege (wherein Defendant was ordered to turn over documents that did not even involve communications with counsel) and her Motion to Compel for Improper Objections…
…the Court’s rulings on Ms. Giuffre’s Motion to Compel for Improper Claim of Privilege (wherein Defendant was ordered to turn over documents that did not even involve communications with counsel) and her Motion to Compel for Improper Objections…