…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…
…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 …
…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 …
…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 …
…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…
…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…
…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 …
…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…
…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…
…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…
…Did you ever see the photo after it was 8 taken? 9 A. I did not. 10 Q. And Ms. Maxwell was present during the -- 11 was Ms. Maxwell present during that? 12 A. Yes. 13 Q. What happened next…
…she was recruited to join Epstein's harem in 1999 by his friend, the socialite Ghislaine Maxwell. She says during the three years she worked for Epstein, she was made to entertain his friends and named Prince Andrew and Dershowitz…
…Did you ever see the photo after it was 8 taken? 9 A. I did not. 10 Q. And Ms. Maxwell was present during the -- 11 was Ms. Maxwell present during that? 12 A. Yes. 13 Q. What happened next…
…4 Q How do you know that? 5 A Because she did not have a job anywhere 6 else. 7 Q How frequently during that period of time 8 would she be going over to Jeffrey epistipes house? 9 MS…
…the complaint, which is based on one claim of defamation, as 7 well as a motion to stay discovery during the pendency of our 8 motion to dismiss the complaint. 9 At the heart of this case, your Honor, defamation…
…witnesses newly identified in her Third and Fourth Revised Rule 26 disclosures. There is no legally principled reason to exclude these topics during Plaintiff’s reopened deposition and Ms. Maxwell should be permitted to examine Plaintiff based on this information…
…time Ms. Alexander has knowledge about matters at issue, including Plaintiff’s whereabouts during 2000-2002 and her false claims concerning Defendant and others. 4. Miles Alexander Address unknown at this time Telephone number unknown at this time Mr. Alexander…
…the complaint, which is based on one claim of defamation, as 7 well as a motion to stay discovery during the pendency of our 8 motion to dismiss the complaint. 9 At the heart of this case, your Honor, defamation…
…recall.” For example, when faced with the police report which contains statements from approximately thirty (30) different victims during a time frame which the Defendant acknowledges she was actively working for Epstein at his various homes, Defendant challenged the veracity…
…Did you ever see the photo after it was 8 taken? 9 A. I did not. 10 Q. And Ms. Maxwell was present during the -- 11 was Ms. Maxwell present during that? 12 A. Yes. 13 Q. What happened next…
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