…Respondent(s) in this action. At that time and place, you also shall produce the following items now in your custody or control: See attached Schedule A ______ Names, addresses and telephone numbers of all counsel of record in this action…
… AND UNSEAL ALAN M. DERSHOWITZ declares under penalty of perjury that the following is true and correct: 1. I am personally familiar with the facts set forth in this Reply Declaration, which I submit in further support of my pending…
…Plantation, Florida 33324-4413 (Name ofperson to whom this subpoena is directed) ~ Production: YOU ARE COMMANDED to produce at the time, date, and place set forth below the following documents, electronically stored information, or objects, and to permit inspection…
…05/24 Page 2 of 26 **ROUGH***Deposition of Tony Figueroa*** ROUGH*** 1 1 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF 2 Virginia L. Giuffre v. 3 Ghislaine Maxwell 4 The following transcr…
… AND UNSEAL ALAN M. DERSHOWITZ declares under penalty of perjury that the following is true and correct: 1. I am personally familiar with the facts set forth in this Reply Declaration, which I submit in further support of my pending…
…April 07, 2016 12:01 PM To: Martin Weinberg Subject: RE: Giuffre v. Maxwell No -I can wait until tomorrow. Thank you for following up. Sigrid Sigrid S. McCawley· Partner BOIES, SCHILLER & FLEXNER LLP 401 East Las Olas Blvd., Suite…
…East Las Olas Boulevard, Suite 1200, Fort Lauderdale, Florida 33301, within thirty (30) days of service hereof. DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: 1. “Agent” shall mean any agent, employee, officer, director…
…Meredith: I write to confirm our oral conferral. Please let me know if you disagree with the following or if there is some other agreement you think we reached: 1. I will endeavor to have my client gain access to…
…DISCLOSURES Pursuant to F.R.C.P. 26(a)(l)(A), Defendant Ghislaine Maxwell makes the following disclosures: I. IDENTITIES OF INDIVIDUALS LIKELY TO HAVE DISCOVERABLE INFORMATION RELEVANT TO DISPUTED FACTS ALLEGED WITH PARTICULARITY IN THE PLEADINGS 1. Ghislaine Maxwell …
…Defendant. ____________________________/ PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS AND PLAINTIFF’S CROSS DESIGNATIONS Plaintiff Virginia Giuffre, hereby submits the following objections to Defendant’s Deposition Designations and submits the following cross designati…
…Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant ___________________________/ JOINT PRETRIAL STATEMENT Pursuant to this Court’s individual practice rules, the parties hereby submit the following Joint Pretrial Statement as follows: i. Full Caption of the Action Virginia L…
… AND UNSEAL ALAN M. DERSHOWITZ declares under penalty of perjury that the following is true and correct: 1. I am personally familiar with the facts set forth in this Reply Declaration, which I submit in further support of my pending…
…Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ JOINT PRETRIAL STATEMENT Pursuant to this Court’s individual practice rules, the parties hereby submit the following Joint Pretrial Statement as follows: i. Full Caption of t…
…cv-07433-RWS Sigrid, Based on the Court’s rulings on April 21st, and your client’s deposition on May 3rd, please provide the following documents on or before April 27th, 2016. All documents withheld on the basis of…
…07/15/21 Page 5 of 24 To: Ellmax, LLC EXHIBIT A DEFINITIONS Wherever they hereafter appear the following words and phrases have the following meanings: 1. “Plaintiff” in the above captioned action shall…
…3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 29th day of March, 2017, I served the attached document via CM/ECF and e-mail to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca…
…3 of 3 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 28th day of November, 2017, I served the attached document via CM/ECF and e-mail to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca…
…process and afford persons identified or otherwise interested in the Sealed Materials the opportunity to participate in the Court’s individualized review, the Court adopts the following protocol. 1. Non-Parties List: Plaintiff Virginia Giuffre and Defendant Ghislaine Maxwell (collectively…
…on “rotation” for sex with Jeffrey Epstein during the trips to Epstein’s island. For example, non-party Ransome witnessed the following: Q. And when you say you were on rotation, you mean you were having sex with Jeffrey multiple…
…by and through her counsel, hereby submits the following Response in Opposition (“Response”) to Plaintiff’s Motion to Enforce the Court’s Order and Direct Defendant to Answer Deposition Questions Filed Under Seal (“Motion”), as follows: INTRODUCTION This lawsuit presents…