…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…
… 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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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 …
…bunch of photographs. I have looked at them, 11 nothing prurient about them, they all predate the statute of 12 limitations time period and were used during the deposition. 13 THE COURT: Yes, but generically I am correct, am I…
…and other physical evidence, or information of a similar nature. (b) During discovery, interrogatories other than those seeking information described in paragraph (a) above may only be served (1) if they are a more practical method of obtaining the information…
…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........…
…Nadia Macinkova, and various other girls and guests he brought to the island. 3. During one ofmy visits to the island I met Ghislaine Maxwell. Watching her interact with the other girls on the island, it became clear to me…
…active investigations involving Ghislaine Maxwell,” counsel for Defendant unearthed numerous records of such contacts. In the time period just before and during her alleged “sexual slavery” to Jeffrey Epstein and Ghislaine Maxwell, Plaintiff interacted with law enforcement on numerous occasions. …
…from 2000 - 2002. Defendant has denied that she used those accounts to communicate, but she has not disclosed the account she did use to communicate during that time, nor produce documents from it. Case 1:15-cv-07433-LAP…