…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…
…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…
…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…
…6, 7 Lytle v. JPMorgan Chase, 810 F. Supp. 2d 616 (S.D.N.Y. 2011) ................................................................................................ 3, 6 Natixis Financial Products LLC v. Bank of America, N.A., 10 Civ. 3656, 2016 WL 7165981 (S.D.N.Y., Dec. 7…
…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 Does 73 and 93 were not “involved in any of the conduct underlying this action” or “accused of any wrongdoing” because they worked for Epstein in a “financial capacity” or because Plaintiff could not remember their names at deposition. …
…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…
…to why certain portions of her deposition are “personal,” “most of the cases in which courts have concluded that the privacy interests of individuals were sufficient to overcome the presumption of access involve illness or sensitive personal financial information.” Lytle…
…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 …
…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…
… 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…
…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…
…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…