…individual, firm, partnership, association, joint venture, estate, trust, receiver, syndicate, enterprise or combination, corporation or other legal, business or government entity. 12. “Relate,” “relating,” “relates” means concerning, referring to, responding to, relating to, pertaining to, connected with, evidencing, commenting on…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. "Including'' means including ·without limitations. 7. "Jeffrey Epstein" includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…his guilty plea and associated non-prosecution agreement. Dershowitz uniquely would have been aware of the compelling evidence against Epstein — and no doubt would have taken a keen interest in the evidence that would have connected him with Epstein's…
…a past or present officer, director, agent or servant, including any attorney (associate or partner) or paralegal. 6. “Including” means including without limitations. 7. “Jeffrey Epstein” includes Jeffrey Epstein and any entities owned or controlled by Jeffrey Epstein, any employee…
…attending to an Alzheimer's Association event in New York in 2010 2/6 Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 8 of 161 It raises serious questions as to why Maxwell…
…was telling the truth. To prove the truth of her sexual abuse, Ms. Giuffre seeks discovery of documents evidencing her sexual abuse and sexual trafficking by Maxwell and her associates, including convicted sex offender Jeffrey Epstein. Therefore, documents evidencing Ms…
…clear, the only massage I recall receiving at the Epstein home was conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
…clear, the only massage I recall receiving at the Epstein home was conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
…clear, the only massage I recall receiving at the Epstein home was conducted by a professional masseuse—a woman in her in her 30s or 40s. This occurred well outside the timeframe when Ms. Giuffre was associated with Mr. Epstein…
…2015. 2 or disprove the claim in this case.6 Defendant cannot hold the position that documents relevant to the claim in this case arise solely from a self-serving fraction of the requested date range if collected from her…
…and therefore, at most, begin with a presumption of public access “somewhat lower than the presumption applied to material introduced at trial, or in connection with dispositive motions such as motions for dismissal or summary judgment.” Brown v. Maxwell, 929…
…s counsel in England, for purposes of potential litigation in England. Id. Given the time allotted for response in connection with this Motion to Compel Documents Privileges and Plaintiff’s failure to confer regarding this issue, Ms. Maxwell has not…
…asserted with respect to each. Submissions by the parties in connection with this motion have made clear the relationship of authors and addressees to each other with respect to documents for which work-product immunity is claimed. Affidavits submitted in…
…Epstein, a reported billionaire), and multi-million dollar transactions to others in the organization such as Defendant (e.g., the apparent concealed transfer, through an attorney associated with Epstein, of an apartment to Defendant worth, in 2015, $15,000,000)…
…13 and foundation. 13 illegal activity as you've construed in 14 Q. Yes or no? 14 connection with this case I don't have 15 A. No. 15 any problem with you asking that 16 Q. Have you ever…
…examples include: All documents identifying passengers, manifests, or flight plans for any helicopter or plane ever owned or controlled by your or Jeffrey Epstein or any associated entity from 1999 – present. (No. 9) All documents relating to payments…
…inter alia, “to connect or associate, as in thought or meaning; show as having to do with,” “to have some connection or relation (to),” and “to have reference (to)”). Courts have condemned the use of “related to” as overbroad and…
…charged in this Indictment, GHISLAINE MAXWELL, the defendant, had a personal and professional relationship with Jeffrey Epstein and was among his closest associates. In particular, between in or about 1994 and in or about 1997, MAXWELL was in an intimate…
…George Jane Doe 2 Taxi Service/Limo Dan Tischen FedEx # 114420816 (Monday & Thursday) 1800 463 3339 Recycling Every Thursday 6AM to 5PM Trash collection M-F once a day Early Morning Cars Mercedes of Palm Beach …
…Pottinger and defense/common 9/7/2015 [email protected],stan McCawley re collection of information to assist in interest/work 109 18:58 Sigrid McCawley [email protected] providing legal advice re potential litigation product Withhe…