…23/17 Page 2 of 4 The Parties, through their respective counsel, propose the following case management deadlines and request that the Court enter an order modifying its Order of October 3, 2016, ECF #455 for the following reasons: Subsequent…
… 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…
…1096. As to streamlining the process, the parties have agreed upon the following changes to the Protocol: First, to speed up the unsealing process and to minimize the number of Non-Party names that need to be redacted from future…
…07433-LAP Document 1327-12 Filed 01/05/24 Page 2 of 11 Defendant Ghislaine Maxwell (“Ms. Maxwell”) respectfully files the following Submission Concerning Search Terms and Notice of Compliance with Court Order regarding Forensic Examination of Devices, as follows: …
…1108. The Parties met and conferred on July 26, and discussed ways in which the sealing process can proceed more efficiently. The Parties therefore present the following options to the Court. Plaintiff’s Proposal At the July 1, 2021, hearing…
… 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…
…DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(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 …
…including Prince Andrew, after moving to New York in 1991 following the death of her father on his yacht. According to the documents, a woman identified as Jane Doe 3 says Ms Maxwell asked her to visit Epstein’s Florida…
…DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(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 …
…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…
…3 and Jane Doe 4 as Petitioners (“Rule 15 Motion”) (DE 311). Both motions are ripe for review. For the following reasons, the Court concludes that they should be denied. I. Background This is an action by two unnamed petitioners…
…AKT) TYPE OF CONFERENCE: DISCOVERY STATUS CONFERENCE APPEARANCES: Plaintiff Paul C. Whalen Defendant Eamon P. Joyce FTR: 3:31-4:44 THE FOLLOWING RULINGS WERE MADE: 1. As a preliminary matter, the Court addressed Defendant’s motion for an inspection…
…MADE AGAINST PROFESSOR DERSHOWITZ Professor Alan M. Dershowitz today issued the following statement regarding the results of the independent investigation conducted by former FBI Director Louis Freeh of sexual misconduct allegations made against Prof. Dershowitz. STATEMENT OF PROFESSOR ALAN M…
…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…
…Giuffre, by and through her undersigned counsel, respectfully submits the following authority for the application of the privilege claimed regarding her in camera submission, pursuant to the Court’s Order [DE 134] dated May 2, 2016.1 ARGUMENT Statements made…
…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 …
…DISCLOSURES Pursuant to F.R.C.P. 26(a)(1)(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…
…cv-07433-LAP Document 320 Filed 08/01/16 Page 2 of 11 Defendant Ghislaine Maxwell (“Ms. Maxwell”) respectfully files the following Submission Concerning Search Terms and Notice of Compliance with Court Order regarding Forensic Examination of Devices, as follows: …