Found 400 results for “during” in 155ms

gov.uscourts.nysd.447706.1046.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1046.0 3 pg

…NY 10007 Re: Giuffre v. Maxwell, Case No. 15-cv-7433-LAP Dear Judge Preska, Plaintiff writes pursuant to the Court’s instructions during the March 31, 2020 telephone conference, to identify the first five motions for the unsealing process…

gov.uscourts.nysd.447706.1295.8.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.8 9 pg

…Non-party Sarah Ransome, by and through her undersigned counsel, hereby submits this Motion for a Protective Order based on harassing and highly personal discovery sought by subpoena and during her deposition. BACKGROUND On February 6, 2017, Defendant served non…

gov.uscourts.nysd.447706.1210.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1210.0_1 3 pg

…adults and testimony and identifying information of non-party Does who have not been considered for unsealing, the Court considered, as it did during the last round of unsealing, the reliance of these parties on the case’s protective order. …

gov.uscourts.nysd.447706.1100.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1100.1 13 pg

… The Discovery disclosed to the defendant (“Defendant”) and/or to the defendant’s criminal defense attorneys (“Defense Counsel”) during the course of proceedings in this action: a) Shall be used by the Defendant or her Defense Counsel solely for purposes…

gov.uscourts.nysd.447706.1353.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1353.0 6 pg

…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…

gov.uscourts.nysd.447706.1296.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.2 17 pg

…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the …

gov.uscourts.nysd.447706.1078.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.5 161 pg

…LAP Document 1078-5 Filed 07/29/20 Page 6 of 161 Socialite Ghislaine Maxwell 'groped a 16-year-old girl during a naked massage,' victims' lawyer says dailymail.co.uk/news/article-8163681/Socialite-Ghislaine-Maxwell-groped-16-year…

gov.uscourts.nysd.447706.1331.36.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.36 10 pg

…At that deposition, he asserted his Fifth Amendment privilege and declined to answer all substantive questions posed to him during the deposition. The validity of his assertion of the privilege has already been the subject of extensive litigation in this…

gov.uscourts.nysd.447706.1201.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.1_1 17 pg

…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the …

gov.uscourts.nysd.447706.1327.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.5 17 pg

…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the …

gov.uscourts.nysd.447706.1137.1_1_1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.1_1_1_1 10 pg

…counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly ·'adult'' sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case…

gov.uscourts.nysd.447706.143.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.143.0 10 pg

…counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly “adult” sexual activity related to Jeffrey Epstein. Because this activity is highly relevant to this case…

gov.uscourts.nysd.447706.1218.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.1 17 pg

…2016 Sealed Order, filed in redacted version at D.E. 264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the …

gov.uscourts.nysd.447706.1325.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.4 6 pg

…me. We were serving subpoenas on dates that we thought are grouped within the locations/date ranges we discussed during the meet and confer and since we have been having an extraordinarily difficult time serving witnesses who appear to be…

gov.uscourts.nysd.447706.363.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.9 5 pg

…made against me, it concludes that in Judge Freeh’s professional opinion, “The totality of the evidence found during the investigation refutes the allegations made against Professor Dershowitz.” STATEMENT OF LOUIS J. FREEH Over the past several months, an independent…

gov.uscourts.nysd.447706.18.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.18.0 5 pg

…hereby respectfully submits this Memorandum of Law in support of her Motion to Stay Discovery during the pendency of her Motion to Dismiss. LEGAL STANDARD Rule 26(c) of the Federal Rules of Civil Procedure grants courts broad discretion to…

1320-2.pdf PDF

giuffre-maxwell 1320-2 10 pg

…and through her undersigned counsel, hereby files this Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition, Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related to Jeffrey Epstein. Because this activity is highly…

gov.uscourts.nysd.447706.908.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.908.0 4 pg

…In 2011, the Federal Bureau of Investigation (“FBI”) met with Plaintiff Virginia Giuffre at the United States Consulate in Sydney, Australia. During that meeting, Plaintiff informed FBI Special Agents of the existence of multiple original photographs. See Edwards Declaration, FBI…

gov.uscourts.nysd.447706.685.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.685.0 6 pg

…attorneys, Paul Cassell and Brad Edwards, during the trial. This is a transparent ploy to attempt to disrupt Ms. Giuffre’s legal team and should be precluded. FACTUAL BACKGROUND In the upcoming four-week trial of this matter, Ms. Giuffre…

gov.uscourts.nysd.447706.185.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.185.7 26 pg

…DOC 291 thoroughly outlines: (1) The relationship between Dershowitz and Epstein; (2) Dershowitz's role representing Epstein during the criminal investigation of Epstein; (3) Dershowitz's role in negotiating the Non-Prosecution Agreement ("the NPA") between Epstein and the United…

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