…in this single count claim of defamation. Ms. Maxwell has fully responded to all requests for production of documents relating to any and all financial transactions and ties between herself and Mr. Epstein from 1999 to present, including Request Nos…
…entities with (apparently) audited financial statements, the discovery here should be much broader – and should include all of the significant requests made by Ms. Giuffre. For example, Defendant should also be required to identify all financial transactions involving (directly or…
…entities with (apparently) audited financial statements, the discovery here should be much broader – and should include all of the significant requests made by Ms. Giuffre. For example, Defendant should also be required to identify all financial transactions involving (directly or…
…DAMAGES 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. DOCUMENT REQUEST NO. 22 …
…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…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS ...... GHISLAINE MAXWELL, Defendant. --------------------------------------------------X …
…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. …
…following personal data identifiers: Social Security numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information…
…Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ DECLARATION OF SIGRID MCCAWLEY IN SUPPORT OF PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR PROTECTIVE ORDER REGARDING FINANC…
…X .......................................... VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS ...... GHISLAINE MAXWELL, Defendant…
…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…
…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…
…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…
…following personal data identifiers: Social Security numbers; dates of birth; minors’ names; and financial account numbers. See Federal Rule of Civil Procedure 5.2, and Federal Rule of Criminal Procedure 49.1. Parties wishing to request redaction of other information…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…7: Photographs ................................................................................................... 5 D. Request 9-12: Passports, Visas and Other Travel Documents ............................................ 6 E. Request 15-16: Financial Records to Support Her Claims .........................................…
…the subpoena served on Ms. Ransome seeks documents that are wholly irrelevant to the underlying action including protected financial information and documents or communications between Sarah Ransome and her attorneys, which are protected by the attorney- client privilege and the…
…7: Photographs ................................................................................................... 5 D. Request 9-12: Passports, Visas and Other Travel Documents ............................................ 6 E. Request 15-16: Financial Records to Support Her Claims .........................................…