…to answer questions on this subject. And, once again, Ms. Giuffre was forced to move to compel answers. And, once again, the Court ordered Defendant to answer questions about the subjects she had refused to address, enumerating four specific topics…
…basic words (“I don’t know what you mean by puppet”1). As a result, Ms. Giuffre was forced to file a Motion to Compel Defendant to Answer Deposition Questions (DE 143). On June 20, 2016, this Court granted Ms…
…the Court will recall, a Defendant’s initial deposition, . As a result, Ms. Giuffre was forced to file a Motion to Compel Defendant to Answer Deposition Questions (DE 143). On June 20, 2016, this Court granted Ms. Giuffre’s Motion…
…10. This deposition is currently scheduled for July 22, 2016. Ms. Giuffre is forced to take this deposition without the discovery this Court ordered, and therefore, will not be able to depose Defendant on the wrongfully withheld discovery. Additionally, Ms…
…Ms. Maxwell’s denial of those statements substantially true.7 Plaintiff has been forced to admit that her repeated claims and sworn statements that she became a “sex slave” in 1999 when she was 15 years old are untrue. She…
…her counsel to accept service of the subpoena, so Ms. Giuffre was forced to commence the efforts to attempt to personally serve her with the subpoena. As explained in the attached affidavit, the Alpha Group Investigators commenced efforts to personally…
…43 Filed 07/15/21 Page 6 of 12 hasn’t been completed correctly.”) Ms. Giuffre had to then litigate, extensively, to force Defendant to perform a proper collection and search, and, correctly, in response to the Motion to Compel…
…22, 2016, 2 Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 6 of 24 Ms. Maxwell was forced to file a Motion to Compel Plaintiff to Disclose Pursuant to Fed. R. Civ. P…
…Subpoena (pending). Similarly, the Court will recall that Ms. Giuffre was recently forced to resort to the Hague Convention in an effort to depose Maxwell’s spokesman, Ross Gow, about statements he made on Defendant’s behalf. See DE 306…
…22, 2016, 2 Case 1:15-cv-07433-LAP Document 1198-1 Filed 01/27/21 Page 6 of 24 Ms. Maxwell was forced to file a Motion to Compel Plaintiff to Disclose Pursuant to Fed. R. Civ. P…
…Subpoena (pending). Similarly, the Court will recall that Ms. Giuffre was recently forced to resort to the Hague Convention in an effort to depose Maxwell’s spokesman, Ross Gow, about statements he made on Defendant’s behalf. See DE 306…
…her counsel to accept service of the subpoena, so Ms. Giuffre was forced to commence the efforts to attempt to personally serve her with the subpoena. As explained in the attached affidavit, the Alpha Group Investigators commenced efforts to personally…
…22, 2016, 2 Case 1:15-cv-07433-LAP Document 1320-33 Filed 01/03/24 Page 6 of 24 Ms. Maxwell was forced to file a Motion to Compel Plaintiff to Disclose Pursuant to Fed. R. Civ. P…
…her counsel to accept service of the subpoena, so Ms. Giuffre was forced to commence the efforts to attempt to personally serve her with the subpoena. As explained in the attached affidavit, the Alpha Group Investigators commenced efforts to personally…
…March 22, 2016, 2 Case 1:15-cv-07433-LAP Document 231 Filed 06/20/16 Page 5 of 23 Ms. Maxwell was forced to file a Motion to Compel Plaintiff to Disclose Pursuant to Fed. R. Civ. P…