giuffre-maxwell
gov.uscourts.nysd.447706.1218.26
4 pg
…had hired ex-L.A. police detective Mark Fuhrman as a consultant that his title
was changed, GMA chief Shelley Ross confirmed Wednesday.
Fuhrman, who pled out to perjury charges after denying at O.J. Simpson’s 1996 murder trial…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.36_1
35 pg
…am so close to wrapping up an
era, just need a couple dates confirmed is all.
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…filing will be delayed if Andrew accepts the interview request by January 19.
The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to accept the letter to Prince
Andrew and that it was returned to…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.4
35 pg
…am so close to wrapping up an
era, just need a couple dates confirmed is all.
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…The parties have confirmed that Plaintiff’s deposition has yet to be taken
in light of this outstanding discovery dispute.
Having reviewed and considered Defendant’s motion to compel [DE 40] and Plaintiff’s
opposition [DE 41] the Court is…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.39
35 pg
…am so close to wrapping up an
era, just need a couple dates confirmed is all.
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept…
giuffre-maxwell
1320-39
35 pg
…am so close to wrapping up an
era, just need a couple dates confirmed is all.
If you aren't sure about the dates which you have already said that's fine. I have turned the Wilton
Manors police dept…
giuffre-maxwell
gov.uscourts.nysd.447706.69.2
21 pg
…In such a case ‘even where the
plaintiff can show no actual damages at all, a plaintiff who has
otherwise shown defamation may recover at least nominal damages’
and the Second Circuit also confirmed an award of punitive
damages). Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…requested by
Plaintiff, and all responsive documents produced. This expensive, costly and time consuming
exercise in futility simply confirmed that all responsive documents, including all responsive
emails, were produced in March and April 2016.
Most significantly, the devices were searched…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…did not correct this testimony.
In her Reply Brief, Ms. Churcher has confirmed that Professor Dershowitz
was not among the prominent individuals that Ms. Giuffre was accusing of
sexual misconduct. The Reply Brief affirmatively argues that Ms.
Churcher was…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…requested by
Plaintiff, and all responsive documents produced. This expensive, costly and time consuming
exercise in futility simply confirmed that all responsive documents, including all responsive
emails, were produced in March and April 2016.
Most significantly, the devices were searched…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.10_1
27 pg
…spas
nearby, including the Breakers, Boca Raton and Mar-a-Lago, as Mr. Alessi confirmed
when he called them at their jobs to arrange home visits. Id. at 187-88.
The massage therapists were paid by check. Id. at…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…articulated below.2
2
Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an
effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See
…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
… receipt
of the Notice to nearly half of the 91 Non-Parties to whom Ms. Maxwell attempted service was
never confirmed; plaintiff’s counsel has not said how many of the 90+ Non-Parties parties it
served actually received the…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…Party Witness to Produce Documents and Respond to Deposition Questions, and Response
to Motion for Protective Order for Non-Party Witness (ECF 640)1 and further states as follows:
STATEMENT OF CONFERRAL
The undersigned has conferred with Mr. Stanley Pottinger…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…by her own choosing. Deposition by videoconference
will be extremely cumbersome to accomplish given the hundreds of pages of documents to be
1
Defendant conferred with counsel for Plaintiff regarding this Motion prior to its filing. By email of May…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…are unfounded. Ms. Giuffre has repeatedly confirmed that her interest
was that all of the filings in the district court docket should be unsealed so that the public may
have a complete picture of the abuse she suffered. (Dkt. 945…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.4
6 pg
…Lauderdale, FL Oxford, FL
(confirmed) (confirmed)
22 23 24 25 26 27 28
Deposition…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.13
15 pg
…s rendezvous with
Virginia Roberts in Ghislaine Maxwell’s London home, they carried strong disclaimers saying there was no
suggestion of any sexual contact between Prince Andrew and Roberts.”).
6
This is confirmed by the articles themselves. See Churcher Decl…
giuffre-maxwell
1320-10
28 pg
…articulated below.2
2
Ms. Giuffre’s counsel met and conferred with Defendant’s counsel both in person and by phone in an
effort to obtain agreement to proceed with these depositions but was unable to obtain an agreement. See
…
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