Found 21 results for “exploited” in 138ms

gov.uscourts.nysd.447706.1218.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.9 18 pg

… In May 2009, Ms. Roberts filed a civil suit against Mr. Epstein, in which she alleged that Mr. Epstein required that she “be sexually exploited by Defendant’s adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional…

gov.uscourts.nysd.447706.1287.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1287.0 2 pg

…request therein, is resolved by the Court. Document # of Page Line(s) Identifier Redaction Requested Transcript 1283 5 24-25 All text, as explained in Motion No text, as explained in Motion 1283 6 …

gov.uscourts.nysd.447706.1033.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1033.0 1 pg

…unsealed. Plaintiff’s list is identical to Defendant’s list, except that Defendant has failed to include two decided motions: Dkts. 468 & 567. As Plaintiff explained in her February 5, 2020 letter, Dkt. 1029, Judge Sweet decided both motions, and…

gov.uscourts.nysd.447706.1008.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1008.0 5 pg

…1995). As the Second Circuit explained on appeal in this matter, a document is relevant to the performance of the judicial function “if it would reasonably have the tendency to influence Case 1:15-cv-07433-LAP Document 1008…

gov.uscourts.nysd.447706.1295.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.11 19 pg

…2016. Plaintiff’s counsel still has not explained why they waited more than two months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery. 1 BACKGROUND Plaintiff first identified Sarah Ransome…

gov.uscourts.nysd.447706.223.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.223.2 7 pg

…are authorized to accept service of a subpoena for Jeffrey Epstein's testimony in the Maxwell action. You explained that it would be Epstein's position that he would be invoking his Fifth Amendment privilege as to all questions relating…

gov.uscourts.nysd.447706.1331.30.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.30 19 pg

…2016. Plaintiff’s counsel still has not explained why they waited more than two months to disclose the witness, nor why they represented to the Court that she was a “recent” discovery. 1 Case 1:15-cv-07433-LAP…

gov.uscourts.nysd.447706.1332.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.1 42 pg

…The EarthLink account The second account, is, as Ms. Maxwell has repeatedly explained to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever logged onto, and for which she has no password…

gov.uscourts.nysd.447706.1020.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1020.0 7 pg

…frequently was the case, numerous interests could be identified sufficient to rebut the presumption of access. The three counsel of record completed this project within the time constraints imposed by the Court in this expedited proceeding. That is not a…

gov.uscourts.nysd.447706.1295.8.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1295.8 9 pg

…discovery is a valuable right and should not be unnecessarily restricted, the ‘necessary’ restriction may be broader when a non-party is the target of discovery.”). As explained above, this non-party was asked a host of questions that ran…

gov.uscourts.nysd.447706.1330.16.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.16 17 pg

…The second account, , is, as Ms. Maxwell has repeatedly explained to Plaintiff’s counsel, an account that she does not recognize, that she does not recall having ever logged onto, and for which she has no password. See DE 320…

gov.uscourts.nysd.447706.1296.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.12 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.447706.1296.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.9 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.447706.1327.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.12 11 pg

…original search resulted in approximately 9,000 documents and communications containing one or more term in the content or meta-data. The volume of the documents is explained by the breadth of the terms searched, resulting in pulling non-relevant…

gov.uscourts.nysd.447706.1326.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1326.1 45 pg

…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …

gov.uscourts.nysd.447706.1320.13.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.13 45 pg

…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …

gov.uscourts.nysd.447706.1325.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.2 70 pg

…your flight logs and journal. I told him you must remain a confidential source and the way he explained it was that all of the info you pass through me will not be used in court, only as a lead…

1320-13.pdf PDF

giuffre-maxwell 1320-13 45 pg

…try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested in conducting an interview with his client as well as other employees that are employed within the house. Atty. Fronstin advised he would …

gov.uscourts.nysd.447706.320.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.320.0 11 pg

…original search resulted in approximately 9,000 documents and communications containing one or more term in the content or meta-data. The volume of the documents is explained by the breadth of the terms searched, resulting in pulling non-relevant…

gov.uscourts.nysd.447706.218.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.218.0 25 pg

…to sit for a deposition that will presumably cover the same privileged topics. As the New York Court of Appeals explained in its most recent decision on the Shield Law, where “the entire focus” of a reporter’s testimony would…

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