…state and federal law enforcement. 10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre into remaining silent about what had happened to her. 11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”) that…
…state and federal law enforcement. 10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre into remaining silent about what had happened to her. 11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”) that…
…state and federal law enforcement. 10. As part of their sex trafficking efforts, Epstein and Maxwell intimidated Giuffre into remaining silent about what had happened to her. 11. In September 2007, Epstein entered into a Non-Prosecution Agreement (“NPA”) that…
…she told me this, but, did you pay C. as well as whomever she brought to you know, I feel intimidated and so I want to keep the house, pay them both 1 her out. A. No, I pay only…
…the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out… Q. She made a telephone call to you and what precisely did she say? A…
…in order to protect her presidential campaign in 2008. They heavily intimidated her, ruffled her up (luckily she took photos as evidence) and was then forced to sign a confidentiality agreement which ensures that she can never come forward publicly…
… And after you cooperated with the police, 25 you were intimidated by people working for Jeffrey MAGNA9 LEGAL SERVICES Case 1:15-cv-07433-LAP Document 1325-10 Filed 01/04/24 Page 12 of 13 Page 57 1 Jane…
…told me this, but, 19 did you pay C. as well as whomever she brought to 19 you know, I feel intimidated and so I want to keep 20 the house, pay them both? 20 her out. 21 A. No…
…is clear that the qualified privileges do not apply if a speaker deliberately published a false defamatory statement or if the statements are outside the scope of the qualified privilege because their purpose was to bully, harass, and intimidate. Ms…
…Litigation.” ...................14 2. Defendant’s Statements Are Outside The Scope Of The “Pre-Litigation” Qualified Privilege Because They Were Made To Bully, Harass, And Intimidate...................................................…
…do have sworn deposition testimony by her. 7 And most importantly, at page 54 of 57, she testifies 8 that Epstein intimidated her, that his folks tried to get her 9 not to talk, not to cooperate with the police…
…provide to Defendant Epstein. Defendants Maxwell and Epstein also required Plaintiff to engage in sex acts with other females. 45. Defendants Epstein and Maxwell intimidated threatened, humiliated and verbally abused Plaintiffin order to coerce her into sexual compliance. These Defendants…
…the friends for a job and she told me this, but, you know, I feel intimidated and so I want to keep her out… Q. She made a telephone call to you and what precisely did she say? A…
…she told me this, but, did you pay C. as well as whomever she brought to you know, I feel intimidated and so I want to keep the house, pay them both 1 her out. A. No, I pay only…
…...........................................15 II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17 III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL DEPO…
…...........................................15 II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17 III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL DEPO…
…...........................................15 II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17 III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL DEPO…
…...........................................15 II. DEFENDANT’S SUBPOENA SEEKS DOCUMENTS SOLELY FOR THE PURPOSE OF INTIMIDATING AND HARASSING THIS NON-PARTY WITNESS REQUEST 10 (CURRENT PASSPORT/CURRENT VISAS):......................17 III. DEFENDANT SHOULD BE PRECLUDED FROM ASKING ANY ADDITIONAL DEPO…
…should quash the subpoena issued to non-party Jane Doe No. 3 as it is unreasonable and oppressive. The Defendant is abusing the subpoena power in an effort to intimidate, harass and cause undue burden to a non-party. Indeed…
…the broad scope of materials requested, most of which seeks information that is irrelevant to the Defamation Action and clearly intended solely to harass, embarrass, intimidate, and oppress this non-party by seeking highly personal and sensitive information. 2. Ransome…
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