…to and without waiving the above objections, Maxwell is withholding documents outside of the Relevant Periods described in paragraph15, supra, and is withholding production of documents that are privileged pursuant to a common interest agreement. B. Request No. 2 i. …
…videos, notebooks, ledgers, letters, telegrams, cables, telex messages, facsimiles, contracts, offers, agreements, reports, objects, tangible things, work papers, transcripts, minutes, reports and recordings of telephone or other conversations or communications, or of interviews or conferences, or of other meetings, occurrences…
…the work-prod u ctd octrine,Ru le 40 8 of the Fed eralRu les of E vid ence,any common interestprivilege,jointd efense agreementorany other applicable privilege. Case 1:15-cv-07433-LAP Document 79-2 Filed 04…
…already has sued Glenn Dubin, Epstein’s friend, had counsel who was totally cooperative in the rescheduling and reported fanciful and never-before heard claims about Ms. Maxwell, the Dubins and others that he has never reported to any law…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…Jane Doe No. 1 and Jane Doe No. 2 contacted Government counsel to request their agreement to add an additional victim to this case: a young woman Jeffrey Epstein sexual abused when she was under age. On August 20, 2014,…
…First and foremost, the rule was intended to protect a litigant who provides limited amounts of information to government agencies under a confidentiality agreement to gain leniency from the government by demonstrating cooperation. Second, the rule addresses how the inadvertent…
…at which time a Non-Prosecution Agreement was signed between Jeffrey Epstein and the United States Attorney's Office defeming fedsral prosecution of Defendant Epstein and his numerous ceconspirators for identified federal sex crimes against more than 30 minors. 28…
…Police Station and was brought into the interview room for the interview. The door was closed for privacy and she was told that I appreciated her cooperation in this case. During a sworn taped statement,••■~stated she had met Jeffrey…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…category of damage alleged, and the existence, custodian, location and general description of relevant documents, including pertinent insurance agreements, and other physical evidence, or information of a similar nature.” Local Civil Rule 33.3(a). Instead, they seek information under…
…who apparently did not appear on that date with agreement and consent of Plaintiff’s counsel. The remaining three witnesses Plaintiff seeks to untimely depose are ones who repeatedly have expressed their intention to take the Fifth Amendment as to…
…and holding "[A] plaintiff in a civil litigation is bound by the terms of an agreement he has made to restrict the access of non- 3 Case 1:15-cv-07433-LAP Document 1057 Filed 06/10/20 Page…
…who apparently did not appear on that date with agreement and consent of Plaintiff’s counsel. The remaining three witnesses Plaintiff seeks to untimely depose are ones who repeatedly have expressed their intention to take the Fifth Amendment as to…
…E-mail message. If you have received this E-mail in error, please notify the sender and delete the material from any computer. Thank you for your cooperation, Objective Entertainment. From: Virginia Giuffre Jane Doe 2 Sent: Monday, April 04…
…privilege barred a defamation claim premised upon the defendant’s open letter to a newspaper responding to unfavorable publicity against him -- “publicity concededly generated with the cooperation of plaintiffs” -- despite that plaintiff’s claims that the letter “contained numerous untruths…
…your -- 18 your -- your position? 19 A. That's correct. It's been impossible to 20 narrow down exactly what happened because of the lack of 21 cooperation from, for example, Jeffrey Epstein. 22 Q. If as of December 30th…