gov.uscourts.nysd.447706.1219.30.pdf PDF
…DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X .. ............................................. VIRGINIA L. GIUFFRE, …
…of 17 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK --------------------------------------------------X ............................................. VIRGINIA L. GIUFFRE, Plaintiff, v. …
…New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER REGARDING FINANCIAL INFORMATION Plaintiff, Virgin…
…New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER REGARDING FINANCIAL INFORMATION Plaintiff, Virgin…
…well-crafted with the assistance of high-priced attorneys to facilitate Giuffre’s media exposure, to enhance her marketability, to extract financial gain for herself and her family, and to promote her sham non-profit, Victims Refuse Silence, Inc. 2…
…to Enforce Court Order and Direct Defendant to Answer Depo Questions 370: Defendant’s Motion for Protective Order regarding Financial Information 335: Plaintiff’s Motion for Protective Order for Court to Direct Defendant to Disclose Individuals Whom Defendant…
…their demands. For 3 Defendant’s counsel asked the following highly personal and irrelevant information as follows: Personal current financial information from this non-party which information is being sought only for the purposes of harassment. The witness…
…7: Photographs ................................................................................................... 5 D. Request 9-12: Passports, Visas and Other Travel Documents ............................................ 6 E. Request 15-16: Financial Records to Support Her Claims .........................................…
…7: Photographs ................................................................................................... 5 D. Request 9-12: Passports, Visas and Other Travel Documents ............................................ 6 E. Request 15-16: Financial Records to Support Her Claims .........................................…
…10 Ms. Giuffre objects to this interrogatory in that it violates Local Rule 33.3. Ms. Giuffre objects to this request in that it is overly broad and seeks confidential financial information. Ms. Giuffre objects to this interrogatory in that…
…14 2. Allegedly “copyrighted” “proprietary” and “confidential” materials ............................ 15 C. Plaintiff must produce medical information and records, financial information, and employment information and information on other potential causes of her injuries based on her damages claims. .…
…Court, and/or that plaintiff submitted to the Court for no valid purpose. The Sealing Opponents’ reputational (Dershowitz) and financial (the other Opponents) interests are diametrically opposed to Ms. Maxwell’s and the non-parties’. Because of their respective motivations…
…worked for or been in control of Ms. Maxwell. x Ms. Maxwell and Mr. Epstein have had no financial, professional or employment relationship in more than a decade, many years before 2015 when the purportedly defamatory statement was published. Ms…
…assertions about me, other examples of her lack of credibility are relevant. 53. In the first place, Ms. Giuffre has been demonstrated to have made up wildly implausible tales for financial gain. In 2011, for example, Ms. Giuffre was interviewed…
…destroyed Hollywood Prince Charlie Sheen …
…sealed. 19 Doe 73. This Doe worked for Epstein in a financial 20 capacity and there is no allegation that he was involved in any 21 of the conduct underlying this action. Given the sensitive and 22 potentially salacious issues…
…which includes only some of the documents created during discovery, totals in the “thousands of pages”). Giuffre sought and obtained a wide variety of private and confidential information about Maxwell and others, including information about financial and sexual matters. Brown…
…Rule 37 “rejects cases such as Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99 8 Case 1:15-cv-07433-LAP Document 1330-16 Filed 01/05/24 Page 11 of 17 (2d Cir. 2002)5…
…living with her boyfriend. Nevertheless, Defendant insists on moving to compel highly personal financial 17 information from this non-party as set forth in Request 29: “A copy of your most recent paycheck, paycheck stub, earnings statement and any bank…
Comments