…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…
…any purported “privacy interest” in proceeding anonymously. 2 Case 1:15-cv-07433-LAP Document 185-8 Filed 06/01/16 Page 4 of 24 slave” who was sexually trafficked by Jeffrey Epstein (“Epstein”) to his purported associates. Second…
…Enters, Inc., 209 F.3d 163 (2d Cir. 2000) .............................. 17 Club Valencia Homeowners Ass’n, Inc. v. Valencia Associates, 712 P.2d 1024 (Colo. App. 1985) ..................................................................................................................... 13 Cohen v. Stevanovich, 772 F.Supp.2d 416,…
…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…
…Giuffre charged defendant Ghislaine Maxwell, an Epstein associate, with defaming her by publicly calling her statements implicating Maxwell in Epstein’s trafficking “obvious 6 Case: Case:24-182, 24-182,01/08/2026, 07/2…
…a victim of sexual trafficking by financier Jeffrey Epstein. Giuffre charged defendant Ghislaine Maxwell, an Epstein associate, with defaming her by publicly calling her statements implicating Maxwell in Epstein’s trafficking “obvious 6 Case: 24-182, 07/23/2025…
…proof” that Professor Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious allegations against Professor Dershowitz, and used his name in her statements and book proposal, not because he abused her—he didn’t—but because…
…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…
…like to start with 19 Kliman, if I could. 20 Dr. Kliman is a summary witness who has no firsthand 21 knowledge about the facts associated with this case. He's been 22 proffered as an expert in psychiatry. And…
…Central Park Five” case in connection with the civil lawsuit by the individuals who were wrongfully convicted in that case. The City argued that the privilege did not apply because the filmmakers first conducted interviews with one of the plaintiffs…
…like to start with 19 Kliman, if I could. 20 Dr. Kliman is a summary witness who has no firsthand 21 knowledge about the facts associated with this case. He's been 22 proffered as an expert in psychiatry. And…
…proof” that Professor Dershowitz had ever done anything wrong; and that Ms. Giuffre concocted her malicious allegations against Professor Dershowitz, and used his name in her statements and book proposal, not because he abused her—he didn’t—but because…
…2 1. Ms. Giuffre’s Counsel’s Communications With the Media Are Outside the Scope of Rule 26 and Any Attempt at Collection Would be Unduly Burdensome ..............................................................................2 …
…email accounts. In particular, Defendant has not collected data from her account nor produced relevant documents from her account. Both email accounts are listed as part of Defendant’s contact information gathered by the police from Epstein’s home, and…
…and get through Internet. 18 Q. Okay. So, is it your understanding that 19 the only connection then through Citrix with these 20 computers, these various computers that were in 21 Mr. Epstein's home, w…
…this litigation or that her dream journal had anything related to this litigation within it. Ms. Giuffre performed a diligent search for all documents even potentially connected to - this case. She produced a 141 page manuscript from her electronic files…
…Defendant. Accordingly, given Defendant’s extraordinary economic resources, her high-level social connections, and her elaborate residential email/internet configuration she had during that time, it is extraordinarily unlikely that she would not employ an almost ubiquitous communication tool, nor…
…Defendant. Accordingly, given Defendant’s extraordinary economic resources, her high-level social connections, and her elaborate residential email/internet configuration she had during that time, it is extraordinarily unlikely that she would not employ an almost ubiquitous communication tool, nor…
…gathered in course C of investigations into incident – Dominant purpose of investigations so that solicitors could provide legal advice in connection with expected proceedings – Implied statutory duty to investigate but no duty to report – Affidavits did not enable court to…
…23, 2021). In doing so, the Government represented that “[s]uch materials will be used solely in connection with the above-referenced grand jury investigation.” Id. at 4. Judge 1 The assigned district judge in this case, the Honorable Robert…
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