…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…
…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. …
…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 .........................................…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…abuse of Ms. Giuffre, Ms. Giuffre has long been attempting to depose him in the action. Epstein, who is generally regarded as having vast financial resources, evaded those efforts to be served. Accordingly, on May 25, 2016, Ms. Giuffre sought…
…was convicted after a public trial; classes of victims have litigated public lawsuits against Jeffrey Epstein and his co-conspirators (including against several of his financial institutions); and the public and its elected officials have made uncovering details about Epstein…
…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…
…an adverse inference. Likewise, Mr. Epstein has no stake in the outcome of this litigation, financial or otherwise. Nor has he participated in this litigation in anyway. Rather, he completely refused to participate, moving to quash his deposition, pleading the…