…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex abuse conspiracy); see also Plaintiff Giuffre’s Reply…
…Id. at 1. But it should not come as a surprise that those “non-parties,” including those implicated as potential abusers within Jeffrey Epstein’s sex-trafficking conspiracy, would seek to obscure as much information concerning their conduct as possible…
…R. Civ. P. 24............................................................................................................................. 7 5 Case 1:15-cv-07433-LAP Document 1259 Filed 07/28/22 Page 6 of 17 MEMORANDUM OF LAW …
…present Assistant United States Attorney—at the United States Consulate in Sydney, Australia, as part of an ongoing investigation into Jeffrey Epstein sexual abuse and sex trafficking conspiracy. In due course, a Special Agent prepared a standard summary of Ms…
…time. 1 Case 1:15-cv-07433-RWS Document 315 Filed 07/29/16 Page 2 of 17 and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”). 2 Case 1:15-cv…
…time. 1 Case 1:15-cv-07433-LAP Document 315 Filed 07/29/16 Page 2 of 17 and a primary co-conspirator and participant in his sexual abuse and sex trafficking scheme”). 2 Case 1:15-cv…
…Kellen was specifically identified by the U.S. Attorney’s Office for the Southern District of Florida as a “potential co-conspirator of Epstein” in the non-prosecution agreement it executed with Mr. Epstein as part of his guilty plea…
…Giuffre’s efforts to obtain depositions have been hampered by a number of factors. An example of the conduct that has hampered Ms. Giuffre’s efforts to timely obtain depositions is stall tactics of Defendant’s co-conspirator, Jeffrey Epstein…
…Giuffre and never had sex with her, but he is entitled to prove that the allegation fails for other reasons as well). Giuffre has further alleged that Dershowitz was a “co-conspirator” of Jeffrey Epstein and Ghislaine Maxwell, id. at …
…1332-14 Filed 01/08/24 Page 4 of 9 including Defendant’s coordination of the press attack on Ms. Giuffre and Defendant’s coordination of the attack with her co-conspirator, Epstein. The Court heard oral argument on Ms…
…Menninger Decl. Exhibit G shows an email chain containing six communications she had with , an alleged co-conspirator, yet only two of those emails were produced. The emails produced are in “screenshot” format rather than providing a complete production of…
…between Mr. Epstein and 12 the U.S. Attorney's office mentions people that are 13 called co-conspirators of Epstein. And Leslie Groff 14 is named as one of those co-conspirators. 15 …
…privilege. Additionally, these documents are relevant to the underlying litigation in their own right, as they show the nature of the ongoing relationship between Defendant and her co-conspirator, Jeffrey Epstein, and between and Defendant and Epstein’s close friend…
…between Mr. Epstein and 12 the U.S. Attorney's office mentions people that are 13 called co-conspirators of Epstein. And Leslie Groff 14 is named as one of those co-conspirators. 15 …
…Defendant’s Resp. at 3. Tellingly, Defendant’s response brief cites no authority to refute that proposition that adverse inference can be drawn against co- conspirators. Presumably this is because, as recounted in Ms. Giuffre’s opening brief (at pp…
…12. 13. Ms. Maxwell denies that she was a co-conspirator of Epstein and is without knowledge or information sufficient to form a belief as to the remaining allegations contained in Paragraph 13. 14. Ms. Maxwell is without knowledge or…
…Menninger Decl. Exhibit G shows an email chain containing six communications she had with Natalia Malyshev, an alleged co-conspirator, yet only two of those emails were produced. The emails produced are in “screenshot” format rather than providing a complete…
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