…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…
…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 …
…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…
…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…
…party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)). Furthermore…
…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 …
…party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)). Furthermore…
…reasonable trier of fact could find that it would support that claim or defense.” Id. citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002). An adverse inference is appropriate regarding the documents 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…
…19 object on behalf of the 20 plaintiff, Virginia Giuffre, to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked…
…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…
…party's claim or defense such that a reasonable trier of fact could find that it would support that claim or defense.” Id. (citing Residential Funding Corp. v. DeGeorge Financial Corp., 306 F.3d 99, 108 (2d Cir. 2002)). Furthermore…
…19 object on behalf of the 20 plaintiff, Virginia Giuffre, to 21 the extent that you're requesting 22 from a nonparty financial 23 information, which is not allowed 24 under New York law. 25 MS. MENNINGER: I have asked…
…me that there is a 19 not to answer the question. Nice try. 19 financial arrangement between Jean-Luc Brunel and 20 Instruct you not to answer based on 20 Jeffrey Epstein, do you not? 21 your Fifth Amendment privilege…