…Introduction Plaintiff cannot meet the merits of Ms. Maxwell’s well-founded objections to the release her July 2016 compelled deposition testimony or information concerning various Non-Parties, all of whom relied on the Protective Order issued by the Court…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…Motion for Sanctions (“Sur-Reply”), stating as follows: INTRODUCTION Plaintiff’s Response and Sur-Reply are founded entirely on a miscomprehension of the requirements of Federal Rules of Civil Procedure 26 and 33. She strenuously argues that she has “disclosed…
…doesn’t appear to be on the binder index. Attached is what I found in the unredacted e-mail distribution for this date. I believe you should now have everything you need. Please do not hesitate to contact me should…
…cv-07433-LAP Document 1199-26 Filed 01/27/21 Page 3 of 4 Page 194 1 JOSEPH RECAREY - CONFIDENTIAL 2 MS. SCHULTZ: Object to form and 3 foundation. 4 THE WITNESS: And Venero, Christina 5 Ve…
…New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Confidential Page 163 1 G. Maxwell - Confidential 2 and foundation. 3 A. Can you re…
…of sexual contact or relationship" with the woman. "Any claim to the contrary is false and without foundation." Andrew is a son of Queen Elizabeth II and a brother of Prince Charles, the next in line for the British throne…
…New York. - - - MAGNA LEGAL SERVICES 1200 Avenue of the Americas New York, New York 10026 (866) 624-6221 Confidential Page 163 1 G. Maxwell - Confidential 2 and foundation. 3 A. Can you re…
… Case 1:15-cv-07433-LAP Document 526 Filed 01/05/17 Page 2 of 5 TABLE OF CONTENTS INTRODUCTION .......................................................................................................................... 1 ARGUMENT ...................................................…
…and on a Caribbean island owned by Epstein. A Palace spokesman has said that the allegations are "false and without any foundation." "It is emphatically denied that the Duke of York had any form of sexual contact or relationship with …
…doesn’t appear to be on the binder index. Attached is what I found in the unredacted e-mail distribution for this date. I believe you should now have everything you need. Please do not hesitate to contact me should…
…have higher internet usage, including many demographics to which Defendant belongs. For example, higher rates of internet usage are found among younger adults (Defendant was 38 in 1999); those with college educations (Defendant has a master’s degree); those in…
…12 you learn in terms of Ghislane Maxwell's 13 involvement, if any? 14 MR. PAGLIUCA: Object to form and 15 foundation. 16 THE WITNESS: Ms. Maxwell, during her 17 research, was found to be Epstein's long-time 18 …
…Doc.892, at 4-10. It found that “the parties and multiple deponents have reasonably relied on the Protective Order in giving testimony and producing documents including evidence of assault, medical records, and emails,” and “[t]hird-party witnesses have…
…if any? THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein's long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein's home.” 2 …
…also ordered Defendant to produce documents to Ms. Giuffre by July 11, 2016. (This part of the Court’s Order is not under seal and can be found at DE 264-1). On June 30, 2016, and on July 8…
…if any? THE WITNESS: Ms. Maxwell, during her research, was found to be Epstein's long-time friend. During the interviews, Ms. Maxwell was involved in seeking girls to perform massages and work at Epstein's home.” 2 Case…
…in Colorado and avoid service, but we found her and we served her and now she'll be subjected to a deposition," he said. "And if she repeats what she said previously under oath, she will go to jail because…
…Bryan, 339 U.S. 323, 331-32 (1950) (elaborating the importance of balancing “the great power of testimonial compulsion” against exemptions “grounded in a substantial individual interest which has been found, through centuries of experience, to outweigh the public interest…
…insufficient to render that paper a judicial document subject to the right of public access.” She proclaimed that “[a] review of the case law reveals that every circuit to have directly addressed this point has found that documents 1 Ms…
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