gov.uscourts.nysd.447706.1328.2.pdf PDF
…in 11 the investigative incident report? 12 A. I'm not sure if it was updated or not. 13 MR. PAGLIUCA: I don't know if we want to 14 mark this or not. I can hand you what I…
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gov.uscourts.nysd.447706.562.2.pdf PDF
…Alan Dershowitz, defamed them by repeatedly claiming in worldwide media broadcasts and other widely-disseminated statements that they had engaged in conspiring with their client to make up sexual abuse allegations against Dershowitz. The pleadings and discovery taken to date…
gov.uscourts.nysd.447706.1327.29.pdf PDF
…sticking out 10 in your brain as being topless? 11 A. Yes. 12 Q. And the walls on the staircase to the 13 upstairs were not just covered with nude 14 photographs, to your recollection? 15 A. To my recollection…
gov.uscourts.nysd.447706.1325.1.pdf PDF
…had already gathered. Providing this information to third parties waived any qualified privilege that ever arguably existed. Finally, to the extent that any information sought is covered by the qualified protection of Civil Rights Law § 79–h(c)1, Ms…
gov.uscourts.nysd.447706.831.0_2.pdf PDF
…You're very diligent. Maybe overly diligent. 7 Well, anyhow, whatever you are, I'm going to break 8 that up, I think. Plan to stay for another day next week. I 9 think also today, it probably makes sense…
gov.uscourts.nysd.447706.43.0.pdf PDF
…discovery, rather than properly respond to Ms. Giuffre’s discovery, Defendant stonewalled, lodging a litany of baseless objections including a substantial and unjustified reduction of the date range covered by the requests. Ms. Giuffre’s requests were served in October…
gov.uscourts.nysd.447706.45.0.pdf PDF
…explanation for her expansive time frame as discussed below. The gist of Plaintiff’s temporal relevance argument is that, according to Plaintiff, Ms. Maxwell communicated or associated with Mr. Epstein after 2002 up to 2015. And, according to Plaintiff, Mr…
gov.uscourts.nysd.447706.1330.1.pdf PDF
… My deposition testimony includes the following information that Mr. Edwards and I relied upon in believing the truth of Giuffre’s allegations: a. The Palm Beach Police Department put together an 87-page report based on witness interviews and other…
gov.uscourts.nysd.447706.1218.45.pdf PDF
… My deposition testimony includes the following information that Mr. Edwards and I relied upon in believing the truth of Giuffre’s allegations: a. The Palm Beach Police Department put together an 87-page report based on witness interviews and other…
gov.uscourts.nysd.447706.46.0.pdf PDF
…Regarding Ms. Maxwell’s communications with Brett Jaffe in 2011 as noted on the privilege log, she does not dispute that these are covered by the attorney-client communication privilege as defined by New York state law. Mr. Jaffe is…
gov.uscourts.nysd.447706.33.0.pdf PDF
…Corp. 222 F.R.D. 74 (S.D.N.Y. 2003).................................................................................................13 In re Grand Jury Subpoena Duces Tecum Served Upon Shargel, 742 F.2d 61 (2d Cir. 1984) ........................................................................................................10 I…
gov.uscourts.nysd.447706.1296.13.pdf PDF
…to inspection of its electronic servers to locate emails whose existence was speculative. Ms. Ransome’s second argument, the unremarkable position that witness interviews are covered by work product protection, does nothing to address the issue in question, i.e.…
gov.uscourts.nysd.447706.1332.9.pdf PDF
…to inspection of its electronic servers to locate emails whose existence was speculative. Ms. Ransome’s second argument, the unremarkable position that witness interviews are covered by work product protection, does nothing to address the issue in question, i.e.…