…certification. More importantly, Plaintiff, in direct contradiction to both the letter and spirit of Rule 37, did not make any effort to confer with Ms. Maxwell’s counsel regarding any of the issues presented in her Motions to Compel. This…
…the CVRA litigation, i.e., The journal thus was relevant to the CVRA litigation as a purported memorialization of, or contradiction to, the factional assertions contained in .1 (Of 1 …
…The journal thus was relevant to the CVRA litigation as a purported memorialization of, or contradiction to, the factional assertions contained in the CVRA Joinder Motion and supporting affidavits.1 (Of 1 Plaintiff now takes the stance that “journal could…
…Sheriff’s Office for the identities and other identifying information of all juveniles as well as Plaintiff’s parents. x January 1998 – In contradiction to Plaintiff’s sworn testimony that she ran away from home at the age of 13…
…her own testimony. For these reasons, Plaintiff’s depositions must be reopened to examine her on newly discovered evidence and her contradictory statements. ARGUMENT “A person who has previously been deposed in a matter may be deposed again, but only…
…Mr. Barton drafted the bulk of the statement. That's not true at all. If the Court looks 18 19 -- at the papers cited by the response, there is no contradiction of Mr. Barton's testimony. Mr. Barton said that…
…Barton drafted the bulk 17 of the statement. That's not true at all. If the Court looks 18 at the papers cited by the response, there is no contradiction 19 of Mr. Barton's testimony. Mr. Barton said that…
…of injuring the plaintiff. One who makes a public attack upon another subjects his own motives to discussion. It is a contradiction in terms to say that the one attacked is privileged only to speak the truth, and not to…
…directly contradicting Plaintiff’s deposition testimony that she was a “sex slave” for 4 years from 1998-2002 and that she was with Epstein constantly during that four year - period. Based on the newly discovered education records and other witness…
…with the aid of British counsel and without having seen Defendant's British law argument, s6bmits an interpretation of British law directly contradicting Defendant's. 4 • • .~ ·f This precarious support provides an insu…
…To date, those (and many other) records have not been produced. Moreover, Plaintiff made substantive and completely contradictory changes to her deposition testimony in errata sheets after the conclusion of her deposition. As well, she was instructed by counsel not…
…Ms. Giuffre provided documents responsive to this request, which included her personal bank records. Defendant takes the contradictory and self-serving position that discovery concerning the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
…Ms. Giuffre provided documents responsive to this request, which included her personal bank - records. Defendant takes the contradictory and self-serving position that discovery concerning the personal finances of Ms. Giuffre is appropriate, yet discovery concerning her own finances is…
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
…in the upcoming weeks. It is currently, however, limited to rebutting the claims of “relevance” made by Plaintiff relating to the at issue waiver. 11 Plaintiff’s argument on this issue is actually internally contradictory. By alleging Fed. R. Evid…
…contradictory evidence – that she and her 15 attorneys’ have spent the last 5 years of unsuccessful litigation and media-spin to concoct. 1 Case 1:15-cv-07433-LAP Document 99 Filed 04/15/16 Page 5 of 22…
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
…records in footnote 4 of her brief on page 11, yet on page 16, Defendant wrongfully states Plaintiff has not produced Dr. Lightfoot’s records. Despite the self-contradictory briefing, Ms. Lightfoot has produced records. See chart above, Giuffre005431-005438…
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