…date. Defendant represents to the Court that there is no undisclosed email address, yet in the following sentence, she begins a three-page description of her undisclosed email account on Epstein’s server that she says she cannot access. Accordingly…
…and on July 8, 2016, counsel for Ms. Giuffre sent letters to Defendant following up on this Order and proposing search terms (attached as exhibits to DE 279). Defendant did not respond. The July 11, 2016, deadline passed without any…
…and on July 8, 2016, counsel for Ms. Giuffre sent letters to Defendant following up on this Order and proposing search terms (attached as exhibits to DE 279). Defendant did not respond. The July 11, 2016, deadline passed without any…
…authorized a subpoena to be served on Ms. Kellen by these alternative means. DE 164-1. Following the Court’s order, Ms. Giuffre effected alternative service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways…
…and on July 8, 2016, counsel for Ms. Giuffre sent letters to Defendant following up on this Order and proposing search terms (attached as exhibits to DE 279). Defendant did not respond. The July 11, 2016, deadline passed without any…
…matter was completed, 1 Ms. Giuffre proposes the following instruction: Defendant had a duty to collect and produce relevant data from her email accounts from 1999 to the present. Defendant failed to collect and produce relevant emails from some of…
…Julie Brown and her colleagues has far exceeded any expectation he had regarding the coverage the Jeffrey Epstein case would receive. On August 9, 2019, following the issuance of the mandate, the Court scheduled a conference for September 4, 2019…
…which can judge his credibility for itself. The Court should unseal Docket Entries 204-3 and 212-3. As to the following docket entries that mention Doe 1 or Doe 2, Maxwell has identified no reason to keep the portions…
…the USVI seeks access to the following sealed documents and unfiled discovery: 3 Case 1:15-cv-07433-LAP Document 1111 Filed 09/01/20 Page 4 of 14 (a) All currently sealed documents filed in support of…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…Page 8 of 8 CERTIFICATE OF SERVICE I HEREBY CERTIFY that on the 13th day of July, 2016, I served the attached document via Email and CM/ECF to the following counsel of record. Laura A. Menninger, Esq. Jeffrey Pagliuca…
…OF SERVICE I certify that on August 29, 2016, I electronically served this Defendant’s Reply in Support of Motion for Protective Order Regarding Personal Financial Information via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz …
…2016, I electronically served this REPLY IN SUPPORT OF DEFENDANT’S MOTION FOR RULE 37(B) &(C) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RULE 26(A) via ECF on the following: Sigrid S…
…1993) (internal citations omitted). The Defendant’s continued systemic foot-dragging and obstructionism – even following the Court’s June 20 Sealed Order and August 10, 2016 Order [DE 352] – makes an adverse inference instruction with regard to Defendant’s documents…
…00490 (S.D.N.Y. filed July 2, 2019). Following his death a month later,1 twenty-three women testified that Jeffrey Epstein abused and trafficked them.2 Previously, “[o]n June 30, 2008, Epstein pleaded guilty to Florida state…
…and nature or treatment. Menninger Decl., Ex. F. Plaintiff has alleged the following categories of damages: (A) “Physical, psychological and psychiatric injuries and resulting medical expenses—in the approximate amount of $102,200 present value”; (B) “Past, present and future…
…to signing all releases for medical providers requested by Defendant, the work associated with compiling the records and following up with providers (as shown by the above chart) clearly demonstrates Ms. Giuffre’s good faith and persistence in her deliberate…
…SERVICE I certify that on July 25, 2016, I electronically served this Defendant’s Sur Sur-Reply in Support of Motion for Rule 37(b) &(c) Sanctions via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meredith Schultz …
…without court action. On February 24, 2016, following this Court’s January 20, 2016 Order lifting the stay on discovery, defense counsel emailed Ms. McCawley detailing deficiencies in Plaintiff’s Initial Rule 26(a) disclosures submitted on November 11, 2015…