…respectfully moves to unseal—in a limited fashion—various materials previously produced by the law firm of Boies Schiller Flexner LLP to the Government pursuant to a Grand Jury subpoena (the “Materials”) during the grand jury investigation of Jeffrey Epstein…
…GIUFFRE DID NOT WAIVE HER ATTORNEY-CLIENT PRIVILEGE BY DENYING FABRICATED EVICENCE DURING HER DEPOSITION................................25 III.EDWARDS AND CASSELL HAVE NOT WAIVED WORK-PRODUCT PROTECTION AND MAXWELL HAS NOT DEMONSTRATED NEED TO PENETRATE THE PROTECTION........…
…Here. .......................................................................................................... 23 II. MS. GIUFFRE DID NOT WAIVE HER ATTORNEY-CLIENT PRIVILEGE BY DENYING FABRICATED EVICENCE DURING HER DEPOSITION. ............................... 25 III.EDWARDS AND CASSELL HAVE NOT W…
…GIUFFRE DID NOT WAIVE HER ATTORNEY-CLIENT PRIVILEGE BY DENYING FABRICATED EVICENCE DURING HER DEPOSITION................................25 III.EDWARDS AND CASSELL HAVE NOT WAIVED WORK-PRODUCT PROTECTION AND MAXWELL HAS NOT DEMONSTRATED NEED TO PENETRATE THE PROTECTION........…
…clear that the U.S. Attorney’s Office for the Southern District of Florida had concealed from Epstein’s victims a non-prosecution agreement (NPA) that they had reached with Epstein. 6. During the litigation, Mr. Edwards and I have…
…clear that the U.S. Attorney’s Office for the Southern District of Florida had concealed from Epstein’s victims a non-prosecution agreement (NPA) that they had reached with Epstein. 6. During the litigation, Mr. Edwards and I have…
…of these deposition transcripts as part of her evidence in the trial of this matter and may alter or amend these counter-designations as a result of evidence presented during the Plaintiff’s case in chief. Subject to the foregoing…
…abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4…
…by the foJlowing conditions and the rcquiremems of this Agreement set forth below, If the United States Attorney should determine. based on reliable evidence, that, during the period of the Agreement, Epcstoin willfully violated any of the condition., of this …
…that Maxwell had defamed her through this and other public statements. Extensive and hard‐fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively…
…abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4…
…the presumption’s relative weight. Much of the work necessarily falls on the two lead defense counsel for Ms. Maxwell during the district court proceedings, both of whom have many other previously scheduled professional obligations. We respectfully submit this work…
…abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4…
…that Maxwell had defamed her through this and other public statements. Extensive and hard‐fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively…
…that Maxwell had defamed her through this and other public statements. Extensive and hard‐fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively…
…that Maxwell had defamed her through this and other public statements. Extensive and hard‐fought discovery followed. Due to the volume of sealing requests filed during discovery, on August 9, 2016, the District Court entered a Sealing Order that effectively…
…abuse victim of Epstein) telephoned Epstein and scheduled Jane Doe #4 to go to Epstein’s house to give him a massage. During that call, Epstein himself got on the phone (a means of interstate communication) with Jane Doe #4…
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