…get back to him. The Judge has required for conferrals to occur after a writing which spells out the nature of a dispute. There is no such communication from you prior to filing this Motion. The motion is classic deflection…
…v. 15-cv-07433-RWS ...... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of …
…subjects covered by the emails. Moreover, despite having access to other email communications that are similar in nature and substance to the two email communications Plaintiff now claims are “key” documents, Plaintiff elected to not examine Ms. Maxwell on those …
…EXHIBIT 1 Case 1:15-cv-07433-LAP Document 288-1 Filed 07/15/16 Page 3 of 4 nature of a dispute. There is no such communication from you prior to filing this Motion. The motion is classic deflection…
…s Revised Supplemental Privilege Log dated April 29, 2016 including J. Stanley Pottinger in the communications. 5. Attached as Exhibit D is a printout of the content of Stan Pottinger’s Official Website, found on the internet at http://stanpottinger…
…of Obtaining an Adverse Inference, ECF #608, hearing on Plaintiff's Motion to Compel all Work Product and Attorney Client Communications with Philip Barden, ECF #637, hearing on outstanding motions including Motion to Quash Edwards Subpoena, filed in the Southern…
…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…
…Production Ms. Maxwell served Responses and Objections to Plaintiff’s First Discovery Requests on February 8, 2016. Those requests sought, inter alia: x all communications with thirteen specific witnesses, namely Jeffrey Epstein, Virginia Roberts, Prince Andrew, Ross Gow, Alan Dershowitz…
…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…
…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…
…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…
…Any communications with counsel for the purpose of seeking/receiving legal advice related to bringing a Case 1:15-cv-07433-LAP Document 59 Filed 03/15/16 Page 2 of 5 claim are privileged under the attorney-client…
…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…
…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…
…this inquiry, an attorney may rely, when appropriate, on representations by his client or communications with other counsel involved in the case.”) (internal citations omitted). Pl’s Opp’n to Def’s M. Compel (Doc. # 78) at 19. Based on…
…the defendant has used Skype, G-Chat (or if they used Microsoft where some transcripts may have been kept) or some similar communications service which might contain identifiable or responsive information to the discovery requests served. Plaintiff believes to the…
…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…
…and asked that they be searched individually (along with “wild card character searches”), even though, as described above there were only 13 specific witnesses for whom Plaintiff had actually sought all communications. For example, Plaintiff wanted the names 3 …
…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 attorneys’ files and has based her entire Supplement on this fundamental misrepresentation. Likewise, Plaintiff misconstrues and misrepresents many other facts concerning Ms. Maxwell’s communications with other witnesses and with regard to her email accounts. The Court has limited…