…s lost wage claims puts her employment history, educational history and earning capacity at issue. ...................................................................................................... 19 3. Plaintiff’s compensation for selling information ........................................................... 20 …
…Rodriguez at 24-25. Therefore, her work for Epstein and related entities is relevant. Discovery concerning Maxwell’s compensation, formal or informal, for the work she performed for convicted sex offender Jeffrey Epstein is highly relevant for the entire Relevant…
…164. • Whether Defendant was aware of any interstate or international transportation of women, aged 18 to 28, for purposes of having sex with Epstein where they would receive compensation. Id. at 278-79. • Whether Defendant could recall interacting with anyone…
…burden must take into account the scope of the underlying case. Ms. Giuffre is seeking both compensatory and punitive damages that would total millions of dollars. Against that backdrop, a handful of additional depositions cannot be seen as unduly burdensome…
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