Found 24 results for “exploited” in 273ms

gov.uscourts.nysd.447706.773.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.773.4 5 pg

…t discuss either case. But in a little-noticed 2010 affidavit, given a year after the case was filed, Edwards explained why he thought Trump and other notables involved with Epstein, including former President Bill Clinton, might have relevant information…

gov.uscourts.nysd.447706.1218.49.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.49 27 pg

…not the case. Guests having massages did not have massages in Mr. Epstein’s private bedroom suite. This area was private and off- limits to guests, which I explained to the lawyers during my deposition. Id. at ¶¶ 9-10. 40…

gov.uscourts.nysd.447706.1328.30.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.30 40 pg

… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1328-30 Filed 01/05/24 Page 9 of 40 Page…

gov.uscourts.nysd.447706.1307.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1307.4 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.1320.10.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.10 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.1332.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.7 29 pg

…s needs for discovery, the Court should enter a protective order against further discovery (DE 640) and deny Defendant’s Combined Motion to Compel1 (DE 655). As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not …

gov.uscourts.nysd.447706.1335.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1335.5 12 pg

…or Independent of the Protective Order Ms. Giuffre explained in detail why her application to the Court is timely filed under the Protective Order [DE 62], and will not burden the Court with a recitation of such details and arguments…

gov.uscourts.nysd.447706.562.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.562.2 29 pg

…person's reputation. As the Fourth DCA has explained in upholding a punitive damages award in a defamation case: Florida's unusually high protection of personal reputation derives from the common consent of humankind and has ancient roots. It is…

gov.uscourts.nysd.447706.1320.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.12 179 pg

… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179 Page…

gov.uscourts.nysd.447706.1137.12_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.12_2 28 pg

…including one named "Virginia." Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant's coW1sel sent an email refusing to attend this deposition set for Tuesday…

gov.uscourts.nysd.447706.831.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.831.0_2 59 pg

…phone number. There was no privilege asserted. 15 We asked for her financial information in our opening 16 papers. We explained the relevance of that financial 17 information. There was no response to that relevance argument, 18 your Honor, so…

gov.uscourts.nysd.447706.1328.23.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.23 22 pg

…247, 270 (1981). As explained by the Reporters of the American Law Institute’s Restatement of Torts, when considering the size of punitive damages “[t]he wealth of the defendant is also relevant, since the purposes of exemplary damages are…

gov.uscourts.nysd.447706.1334.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1334.1 29 pg

…s needs for discovery, the Court should enter a protective order against further discovery (DE 640) and deny Defendant’s Combined Motion to Compel1 (DE 655). As explained in Non-Party Ransome’s Motion for Protective Order, Defendant should not …

gov.uscourts.nysd.447706.1331.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.12 10 pg

…And, as this Court has already explained, taking the deposition or a newly-discovered witness cures any prejudice: " [t]his and other courts have adopted the taking of depositions as an appropriate mechanism to address late-disclosed witnesses." NJBJA Ins…

gov.uscourts.nysd.447706.43.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.43.0 15 pg

…Giuffre and others; and Defendant continued to communicate with convicted sex offender Jeffrey Epstein until at least 2015. As explained in Ms. Giuffre’s Motion to Compel, the abuse underlying this case started in or around 6 Defendant contends she…

1320-10.pdf PDF

giuffre-maxwell 1320-10 28 pg

…including one named “Virginia.” Id. at 21. It is anticipated that he will testify consistently with that previous testimony. 3 As explained above, as of today, Defendant’s counsel sent an email refusing to attend this deposition set for Tuesday…

1320-12.pdf PDF

giuffre-maxwell 1320-12 179 pg

… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. MAGNA& LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1320-12 Filed 01/03/24 Page 10 of 179 Page…

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