…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…
…made against me, it concludes that in Judge Freeh’s professional opinion, “The totality of the evidence found during the investigation refutes the allegations made against Professor Dershowitz.” STATEMENT OF LOUIS J. FREEH Over the past several months, an independent…
…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…
…defamation complaint, holding that Cosby’s “suggestion that Plaintiff intentionally lied about being sexually assaulted” could expose plaintiff to “‘scorn or ridicule,” and, therefore, Cosby’s statement could be found to have a “defamatory meaning.” Green v. Cosby, No. CV…
…by Defendant’s Notice of Supplemental Authority, the Hill Court found that Cosby’s statements were not defamatory because they did not “lead to an inference that Plaintiff is a ‘liar and an extortionist.’” In vivid contrast, Maxwell called Ms…
…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…
…May 25, 2016 2:58 PM To: [email protected] ; [email protected] Subject: Fw: Giuffre v maxwell Hi Sigrid. I found the April 11 pre-court morning email, see below. As I emailed earlier, I will either be able…
…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 ...................................................…
… rather, he is trying to find a way to send this victim of sexual trafficking to “jail.” “She was hiding in Colorado…but we found her and she will have to be deposed. The end 1 For the limited…
…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…
…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…
…these matters, and the Court has already found that their privacy interests outweigh any presumption of public access. Those same reasons for denying unsealing continue to apply and to outweigh the public’s interest in this Document. Accordingly, the letter…
…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.” See Schultz…
…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…
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