giuffre-maxwell
gov.uscourts.nysd.447706.1320.40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
1320-40
19 pg
…P. 26(a)(1)(A), Defendant Ghislaine Maxwell makes the following
disclosures:
I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE
INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH
PARTICULARITY IN THE PLEADINGS
1. Ghislaine Maxwell
c/o Laura A. Menninger, Esq…
giuffre-maxwell
gov.uscourts.nysd.447706.363.11
40 pg
…40
Korein Tillery
(http://www.americanlawyer.com/home/id=1202754670719)
$50,000 Punitive Award Given in Attorney Fee Dispute
(http://www.dailybusiness…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.35
10 pg
…Ms. Giuffre was the child victim of sexual abuse, which is undisputed.” (Reply
at 9) If there is one thing this litigation makes clear, it is heavily disputed that Ms. Giuffre was
the child victim of sexual abuse. Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.12_2
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memo1y lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant's inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…rejected exactly the same arguments that are being
made here. This Court explained that “[w]hile bifurcation may be the preferred method of
resolving disputed issues of liability and damages, as it prevents prejudice to the defendants by
keeping financial…
giuffre-maxwell
1320-10
28 pg
…the Fifth. Instead, she testified
that she suffered from a series of memory lapses and could not recall many of the key issues in
dispute in this case. As a result of Defendant’s inability to remember events, a variety…
giuffre-maxwell
gov.uscourts.nysd.447706.172.0
28 pg
…was present with Epstein and Defendant on many occasions at Epstein’s homes in New
York, Palm Beach and the USVI, and he has personal knowledge of the disputed issues in this
case
8. Ross Gow (3 ½ hours). Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.185.7
26 pg
…Fla. 3d DCA 2014). In this case, there is no real dispute that an attorney-client privilege
exists with regard to the conununications between Jane Doe #3 and Plaintiffs. Dershowitz's
argument is that the privilege should be waived. Therefore…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.11
15 pg
…set”
when referring to depositions. In an abundance of caution, to avoid unnecessary disputes and waste of this Court’s
time, the undersigned agreed to revise the brief to remove the language in question. The remainder of this brief is…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.43
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…set”
when referring to depositions. In an abundance of caution, to avoid unnecessary disputes and waste of this Court’s
time, the undersigned agreed to revise the brief to remove the language in question. The remainder of this brief is…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…set"
when refe1ring to depositions. In an abundance of caution, to avoid unnecessary disputes and waste of this Court's
time, the undersigned agreed to revise the brief to remove the language in question. The remainder of this brief is…
giuffre-maxwell
1320-27
15 pg
…set”
when referring to depositions. In an abundance of caution, to avoid unnecessary disputes and waste of this Court’s
time, the undersigned agreed to revise the brief to remove the language in question. The remainder of this brief is…
giuffre-maxwell
gov.uscourts.nysd.447706.590.1
4 pg
…ABC
January 6, 2015 Tuesday
LENGTH: 942 words
HEADLINE: Prince Andrew under pressure as Palace disputes teen sex scandal
claims
REPORTERS: Philip Williams
BODY:
LEIGH SALES, PRESENTER: It's been a few years since Britain's Royal Family has
been…
giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…Using the February 4 Non-Party List as a scorecard, following this approach
would knock out a significant number of docket entries in dispute for Does 1 and 2, as highlighted
below.
Case 1:15-cv-07433-LAP Document…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…Defendant's characterization is untiue.1 But, as the mere
1
Case 1:15-cv-07433-LAP Document 1137-16 Filed 10/22/20 Page 5 of 15
fact of this dispute confinns, this case is going to be…
giuffre-maxwell
gov.uscourts.nysd.447706.562.1
13 pg
…VENUE
2. This is an action for damages in an amount in excess of the minimum
jurisdictional limits of this Court.
3. This Court has jurisdiction over this dispute pursuant to 28 U.S.C. §1332
(diversity jurisdiction) as Giuffre…
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