…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL DATA FROM DEFENDANT’S UNDISCLOSED EMAIL ACCOUNT AND FOR AN ADVERSE INFERENCE INSTRUCTION Plaintiff, Virginia …
…Ms. Giuffre has served discovery requests on Defendant, seeking certain financial information from the Defendant. The requests are narrowly tailored to the time frame related to this case, as the requested information concerns 1 Contemporaneous with the filing of this…
…reason having been provided why this important witness should not have to appear at trial, the motion to quash should be denied. BACKGROUND As the Court is aware from previous briefing, Jeffrey Epstein is an important witness in this case…
…15-cv-07433-LAP Document 561 Filed 01/27/17 Page 2 of 22 TABLE OF CONTENTS Page PRELIMINARY STATEMENT ........................................................…
…for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of Rinaldo Rizzo. 4…
…privately-owned islands in the Virgin Islands were essential to the sex-trafficking enterprise. Little St. James is a secluded, private island, nearly two miles off-shore from St. Thomas with no other residents while Epstein resided there. Id., ¶ 66…
…Ms. Giuffre sought relief from the Court numerous times: 1 Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20) - Defendant’s Motion to Stay - Denied (DE 28). Plaintiff’s February 26, 2016…
…Ms. Giuffre sought relief from the Court numerous times: 1 Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery (DE 20) - Defendant’s Motion to Stay - Denied (DE 28). Plaintiff’s February 26, 2016…
…2 Filed 01/27/21 Page 3 of 10 I also wanted to point out another special syntax with regard to proximity searching. This is a search that finds words within a specified distance from one another. On some software…
…Giuffre sought relief from the Court numerous times: 1 Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 2 of 21 x Plaintiff’s Response in Opposition to Defendant’s Motion to Stay Discovery…
…and Failure to Comply with Rule 26(a). 2. Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff’s Response and Objections to Defendant’s First Set of Discovery Requests to Plaintiff, served March 16…
…and Failure to Comply with Rule 26(a). 2. Attached as Exhibit A is a true and correct copy of excerpts from Plaintiff’s Response and Objections to Defendant’s First Set of Discovery Requests to Plaintiff, served March 16…
…9-12, 21-23 (“[W]hat we are looking for from you is a specific 1 Plaintiff is cognizant of the Court’s directive not to file lengthy briefs on every document throughout the course of the unsealing process. Tr…
…1997); see also McComb v. Jacksonville Paper Co., 336 U.S. 187, 191 (1949) (“The absence of wilfulness does not relieve from civil contempt . . . . Since the purpose is remedial, it matters not with what intent the defendant did the prohibited…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
…future pain and suffering, mental anguish, humiliation, embarrassment, loss of self-esteem.” Plaintiff’s claims for these categories of damages must be stricken or evidence as to these damages precluded from trial under Fed. R. Civ. P. 37(b)(2…
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