…Obtaining Discovery ....................................................................................................... 14 B. Plaintiff Refuses To Provide Her Residence, Domicile And Address Where She Lived During Alleged “Defamation.” ...................................................................... 15 C. Plaintiff…
…and proper discovery, through their own self-serving definition of “responsiveness.” As set forth in Dershowitz’s Motion to Compel, Plaintiffs’ interrogatory responses and document production are incomplete, with no date certain as to when they will be completed. Moreover,…
…of an address book containing Dershowitz's name and contact information which an Epstein associate characterized as "the Holy Grail;" and (7) Numerous demonstrably incomplete flight manifests showing that Jane Doe No. 3 was transported on Epstein's private plane…
…19 3. Plaintiff’s compensation for selling information ........................................................... 20 4. “Defamatory” actions by others is relevant.................................................................... 20 D. Plaintiff’s incomplete and evasive answers are improper. .......................…
…the false statements to be issued to various media outlets. Ms. Giuffre has not had the opportunity to depose Maxwell’s agent Ross Gow; therefore, this answer remains incomplete. Consequently, Ms. Giuffre reserves the right to modify and/or supplement…
…7, and 8, as discussed below, the productions are incomplete and an unknown volume of documents have been withheld. Having purposefully interjected herself into this litigation, and initiating another litigation based on the same allegations about which she now plans…
…Ransome in the deposition in this case. For this reason, the deposition transcript standing alone leaves an incomplete and, thus, false impression of Ms. Ransome and her outrageous claims. This Court should not allow its power to enter and modify…
…documents over the course of a month but (b) keep Ms. Maxwell’s deposition on March 25, 2016, despite her incomplete and untimely production, and incorrectly stating that Ms. Maxwell had demanded she “cancel” her deposition. (Doc. # 59 at 3) …
…402 and 403, any admission of this incomplete deposition would be improper. 16 Case 1:15-cv-07433-LAP Document 1331-7 Filed 01/05/24 Page 19 of 21 Like Mr. Rodriguez was expansively questioned based on counsel…
…F, at 41:5-18 (emphasis supplied). An admittedly incomplete and incorrect “manuscript” cannot serve as the “best evidence” of anything. Second, the book manuscript differs in dramatic respects from her CVRA joinder motion. In the Joinder Motion, Plaintiff alleged…
…7, and 8, as discussed below, the productions are incomplete and an unknown volume of documents have been withheld. Having purposefully interjected herself into this litigation, and initiating another litigation based on the same allegations about which she now plans…
…Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in…
…Id. B. Plaintiff’s Counsel Has Repeatedly and Publicly Filed In This Case Numerous Publicly Available Police Reports With Redacted Juvenile Information In complete contradiction to her legal position in this Motion, Plaintiff and her counsel have repeatedly filed in…
…had some remarkable memory lapses during earlier depositions, feigned incomprehension of common words such as “puppet,” as well as repeatedly requesting that questions be re-asked or clarified, over and over and over again, when the those questions were clear…