…and many requests have no date restrictions whatsoever. See, e.g., Request No. 26, “All Documents concerning any prescription drugs taken by You, including the prescribing doctor, the dates of said prescription, and the dates of any fulfillment of any…
…custody and control that would demonstrate Maxwell traveling with underage females but to date she has refused to produce this information and indeed is limiting her responses to a very narrow window of time. 5 with various sexual abuse allegations…
…msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 Case 1:15-cv-07433-LAP Document 156-1 Filed 05/20/16 Page 3 of 26 Log …
…msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016 Case 1:15-cv-07433-LAP Document 1326-3 Filed 01/04/24 Page 3 of 27 Log …
…msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016 Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 3 of 27 Log …
…msg Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated May 27, 2016 Case 1:15-cv-07433-LAP Document 1320-15 Filed 01/03/24 Page 3 of 27 Log …
…cases Plaintiff Virginia Giuffre's Revised Supplemental Privilege Log dated April 29, 2016 Case 1:15-cv-07433-LAP Document 165-1 Filed 05/26/16 Page 3 of 6 Log …
…privilege. However, Ms. Giuffre is continuing to search for additional responsive documents. Defendant propounded 57 requests for production (including subparts), with the date range spanning 18 years or longer. Accordingly, as this search goes on, the undersigned is aware that…
…On May 9, 2016, the parties conferred regarding deposition scheduling and Ms. Giuffre noticed depositions in accordance with the dates and locations that Defendant’s counsel said were available, and, on May 17, 2016, provided her with a calendar outlining…
…On May 9, 2016, the parties conferred regarding deposition scheduling and Ms. Giuffre noticed depositions in accordance with the dates and locations that Defendant’s counsel said were available, and, on May 17, 2016, provided her with a calendar outlining…
…On May 9, 2016, the parties conferred regarding deposition scheduling and Ms. Giuffre noticed depositions in accordance with the dates and locations that Defendant’s counsel said were available, and, on May 17, 2016, provided her with a calendar outlining…
…men with ample resources are employing lawyers and occupying space and time in the justice system to continue their personal feud. Regrettably there is to date no apparent basis to avoid the unappetizing task of ruling on these motions.”). Moreover…
…Defendant. I ---- ---' PLAINTIFF'S Sl-DALED AGHEEI> MOTTO~ TO FILE MOTTON TO COMPEL THE PRODUCTION OF DOCUMENTS AND TESTJJ\tONV FROM ,JEFFREY EPSTEIN l JNDER SEAL l'lJHSFANT TO LOCAL RULE 5.4(b) AND MOTION TO PLACE THE …
…communications, meetings or other events or documents that occurred or were created within that time frame, regardless of the date of creation of the responsive Document. 2. This Request calls for the production of all responsive Documents in your possession…
…informed Defendant that she would produce Ms. Ransome for a deposition as a newly-disclosed witness immediately so as to avoid any prejudice or delay in the March 13, 2017 trial date. In short, Ms. Giufii·e acted promptly and…
…does not identify new controlling law, and therefore will not be considered.”). To the extent that this Court has not yet made a sua sponte ruling to strike them from the docket to date, Ms. Giuffre hereby files her reply…
…DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA …
…April 22, 2016, 9:04 a.m., on the above date , before Leslie Fagin, a Court Reporter and Notary Publ i c in the State of New York. MAGNA LEGAL SERVICES 120 0 Avenue of the Americas New York, New…
…commencing April 22, 2016, 9:04 a.m., on the above date , before Leslie Fagin, a Court Reporter and Notary Public in the State of New York. MAGNA LEGAL SERVICES 12 00 Avenue of the Americas N…
…DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK CASE: 15-cv-07433-RWS VIRGINIA GIUFFRE, Plaintiff, v. GHISLAINE MAXWELL, Defendant. ____________________/ VIDEOTAPED DEPOSITION OF TONY FIGUEROA …
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