…DOCUMENT REQUEST NO. 21 Produce all copies of the complaints in any lawsuits that You have filed in any court in which You seek damages or any other financial recovery from 2014 to the present. RESPONSE: Ms. Maxwell objects to…
…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…
… 21 right. 22 BY MR. KlNlN: i 22 BY l'vffi. HOROWITZ: 23 Q. Have you ever heard of the Financial l ! 23 Q. Did you use the…
…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…
…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…
…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…
…19 10. “Income” includes, without limitation, any revenue, payments, compensation, remuneration, financial benefit or support or any other financial consideration, or provision of any other thing of value. 11. “Person” means any natural person, individual, firm, partnership, association, joint venture…
…for business, personal, political, and financial gain, as well as to obtain potential blackmail information. One such powerful individual that Epstein forced then-minor Jane Doe #3 to have sexual relations with was , a close friend of Epstein’s …
…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…
…that he was a philanthropist who would help female victims advance their careers and lives; and that the recruits needed only to provide Epstein with body massages in order to avail themselves of his financial assistance and influence. In fact…
…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…
…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…
…Conveniently, Epstein does not bother to discuss this factor. Presumably this is because of the exceedingly close personal, financial, and social relationships (among other things) between himself and Defendant Maxwell. Defendant is his former girlfriend. She was also his partner…
…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…
…18 In addition, with regard to the financial information, 19 your Honor has directed the defense to produce all of the 20 financial information but just shortly before trial. So we 21 haven't had an opportunity to look at…
…is not targeted to any person, event, or job. The request could be interpreted in many ways and could include any financial, banking or accounting record compiled over a 17-year time frame. As such, the request fails and Ms…