…Maxwell Case no. 15-cv-07433-RWS Dear Judge Sweet, This is a letter motion to exceed the page limits with Ms. Giuffre's Reply in Support of her Motion to Compel Defendant to Produce Financial Information. Ms. Giuffre had…
…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 .........................................…
…agree to unseal the identities of non-party Does where that information is still sealed in Maxwell: As used in this Protective Order, the term “Confidential Information” includes (i) private financial information, such as tax records and bank account numbers…
…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…
…15 15. Defendant also demands items like personal financial documents from this non-party including payments she received from convicted sex offender Jeffrey Epstein and the men he “lent” this minor child out to from 1999 – 2002. See Exhibit 6…
…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…
…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…
…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…
…into a bun Judge Alison Nathan ruled Maxwell was a significant flight risk, citing her 'substantial international' ties and 'extraordinary financial resources' Maxwell appeared via video, accused of grooming girls as young as 14 for Jeffrey Epstein to…
…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 former Harvard Law Professor Alan Dershowitz, a close friend…
…05/24 Page 9 of 22 standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr…
…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…
…20 of 29 Plaintiff to fabricate facts or portions of her stories; and 5) they were not motivated in taking their actions by potential financial gain . Edwards and Cassell point to both communications with Plaintiff and their own work product…
…at length calling the plaintiff in that case, 5 Mr. McNamee, a liar, calling him a liar 25 ways to Sunday, 6 talking about his financial motives, his potential financial 7 gain, et cetera. 8 Likewise, in the Davis v…
…All bank statements, credit card statements, money transfer records, or other statements from any financial institution in Your name, in whole or in part, for the years 2006-2007. 17. Any Docwnents concerning Your residency during the years 2006-2007…
…worked for or been in control of Ms. Maxwell. 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…
…Epstein, correct? A. There were multiple motives. One of the motives was crassly financial. They were trying to line their pockets with money. But as I also said, and I said this over and over again, they profiled me. They…
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