…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…
…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…
…allegations were found to be unfounded by local police. RESPONSE: Ms. Maxwell has no knowledge of any statements made by Mr. Pagliuca during the March 21, 2016 meet and confer and hence has no documents responsive to this Request. Further…
…boarding passes, or any other mode of travel during the time period 2006-2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks…
…boarding passes, or any other mode of travel during the time period 2006-2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks…
…and versions of it have been released with redactions twice since it was filed (Dkts. 1218-12, 1257-12). During the November 18, 2022, hearing, the Court noted that it had conducted a particularized review of this document and preliminarily…
…boarding passes, or any other mode of travel during the time period 2006-2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is a non-party and this requests seeks…
…allegations were found to be unfounded by local police. RESPONSE: Ms. Maxwell has no knowledge of any statements made by Mr. Pagliuca during the March 21, 2016 meet and confer and hence has no documents responsive to this Request. Further…
…Both Marcinkova and Kellen are key witnesses in this action because they were present with Mr. Epstein and Maxwell during the time period when Virginia Giuffre was with Epstein and Maxwell. ARGUMENT A. The Court Should Permit Alternative Service In…
…Request as vague and confusing. Ms. Maxwell is unaware of all illegal activities in which Plaintiff may have been engaged in during the stated time period, and documents concerning those activities are uniquely within Plaintiff’s possession, custody and control.…
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