…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…
…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. …
… 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…
…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 …
…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 …
…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 …
…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…
…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…
…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…
…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…
…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…
…21 Page 3 of 10 Case 1:15-cv-07433-LAP Document 1199-22 Filed 01/27/21 Page 4 of 10 Q. Do you know what happened during the massage appointments with Jeffrey Epstein and Virginia Roberts? A…
…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…
…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........…
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