giuffre-maxwell
gov.uscourts.nysd.447706.370.1
13 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.35
11 pg
…SERVICE
I certify that on February 6, 2017, I electronically served this NOTICE OF SERVICE OF
RULE 45 SUBPOENA AND NOTICE OF DEPOSITION OF SA.RAH RANSOME via Email on
the folJowing:
Sigrid S. McCawley Paul G. Cassell
Meridith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1296.11
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.8
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1295.17
27 pg
…subpoena demonstrates
that Defendant is not even seeking documents relevant to the matter before this Court, and is
instead attempting to obtain backdoor discovery for other actions.
Ms. Ransome’s responses are subject to the following qualifications, explanations, and
objections…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…32. Under that rule, Plaintiff
must establish the following to use all or part of any deposition at trial:
(a) Using Depositions.
(1) In General. At a hearing or trial, all or part of a deposition may be used against…
giuffre-maxwell
gov.uscourts.nysd.447706.1187.0
3 pg
…however, the parties shall append
to the end of the definition of “Confidential Information” in
the protective order the underlined language at the end of the
following excerpt, which makes clear that the parties cannot
agree to unseal the identities…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.33
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.12
29 pg
…Ransome to sit for additional questions. The following are
18
the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome
contends are sought only for the purpose of harassment and intimidation:
Current paycheck records and…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.11
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.9
29 pg
…Ransome to sit for additional questions. The following are
18
the categories of deposition testimony that Defendant seeks for which non-party Ms. Ransome
contends are sought only for the purpose of harassment and intimidation:
Current paycheck records and…
giuffre-maxwell
gov.uscourts.nysd.447706.1296.13
15 pg
…least once,” but that was after she contacted the New
York Post reporter and blames that reporter for sharing her secret. The supposed “following” occurred prior to Ms.
Ransome’s name being identified publicly or to counsel for Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.9
15 pg
…least once,” but that was after she contacted the New
York Post reporter and blames that reporter for sharing her secret. The supposed “following” occurred prior to Ms.
Ransome’s name being identified publicly or to counsel for Ms. Maxwell…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.15
43 pg
…example, at her deposition,
Defendant indicated that she lacked recollection of or was otherwise unable to specifically
answer the following questions: 1
• Whether Defendant observed a female under the age of 18 at Jeffrey Epstein's
home in Palm Beach…
giuffre-maxwell
gov.uscourts.nysd.447706.1354.0
7 pg
…Doe “relied” on the Protective Order, that order made clear that “it may be modified by the Court
at any time for good cause shown following notice to all parties and an opportunity for them to be heard.” Dkt. 62 …
giuffre-maxwell
gov.uscourts.nysd.447706.57.3
39 pg
…of 39
260 West London Pipeline v Total UK [2008] 2 CLC
A
The following cases were referred to in the judgment:
Ankin v London & North Eastern Railway Co [1930] 1 KB 527.
Atos Consulting Ltd v Avis plc (No…
giuffre-maxwell
gov.uscourts.nysd.447706.468.0
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.370.0
17 pg
…Clements “clearly sensitive
and confidential” financial information and so denied the requests with leave to renew following
8
Case 1:15-cv-07433-LAP Document 370 Filed 08/12/16 Page 11 of 17
a decision on the dispositive…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.20
7 pg
…I certify that on August 10, 2016, I electronically served this Motion to Strike Plaintiff’s
Supplement to Motion for Adverse Inference Instruction Based on New Information via ECF on
the following:
Sigrid S. McCawley Paul G. Cassell
Meredith Schultz …
giuffre-maxwell
gov.uscourts.nysd.447706.1219.19
17 pg
…Clements “clearly sensitive
and confidential” financial information and so denied the requests with leave to renew following
8
Case 1:15-cv-07433-LAP Document 1219-19 Filed 07/15/21 Page 11 of 17
a decision on the…