…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…
…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…
…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. …
…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…
…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 …
…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…
…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…
…Q. Tatts, right. 13 But the 17 individuals that you listed in 14 Exhibit 1, none of those individuals ever said the 15 word -- the words "Ghislaine Maxwell" during the 16 course of this investigation to you, correct? 17 MS…
…approaching 13 hours on the record, far more than the presumptive 7 hour limit under the Federal Rules. During that time, Plaintiff has had a full and fair opportunity to depose Ms. Maxwell on the subject matters she claims are…
…to answer certain questions at her deposition and (2) her late production of important emails. These two issues developed as follows. Defendant’s Failure to Answer Certain Questions During her first deposition, Defendant improperly refused to answer certain questions. Accordingly…
…their ability to have the Court perform its review function would contradict the plain terms of the Protocol. Plaintiff knows that many of the Non-Parties timely asserted their privacy interests during the proceedings. These assertions occurred, in many instances…
…given his relationship with Ross and Diane Sawyer. It was during a Sawyer interview on ABC’s PrimeTime Live that the ex-cop said he was sorry for remarks he made that may have influenced the jury to acquit Simpson…
…and everybody had an attorney, and I was 10 not going to be able to speak with them. 11 Q. Okay. During your investigation, what did 12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 …
…to depose. It was Epstein who gave the directions to Maxwell to recruit Ms. Giuffre and bring her to Epstein’s mansions to be sexually abused. At several points during her recent deposition, Ms. Maxwell refused to answer Ms. Giuffre…
…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…
…document basis. Many of these documents have already been reviewed during the review for Does 1 and 2. Case 1:15-cv-07433-LAP Document 1224 Filed 07/28/21 Page 2 of 6 The Honorable Loretta A. Preska…
…not agree to the appointment of a special master to oversee Ms. Maxwell’s third deposition. INTRODUCTION Plaintiff has deposed Defendant for more than thirteen hours of testimony on the record. During the previous depositions, a variety of issues arose…
…American Correspondent of The Mail on Sunday, a publication owned by Associated Newspapers of London, England. During the interim she worked as a freelance reporter for publications including The Mail on Sunday, the U.S. operation of its digital arm…
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