…...........................................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…
…was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex trafficking. 26. On December 30, 2014, Giuffre…
…...........................................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…
…bullying, harassing, and intimidation. This Court has already held that summary judgment based upon an asserted privilege protecting defamatory pre-litigation communications is precluded when a plaintiff raises “a genuine issue as to malice and appropriate purpose.” Block, 691 F…
…was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex trafficking. 26. On December 30, 2014, Giuffre…
…was, and continues to be, to help survivors surmount the shame, silence, and intimidation typically experienced by victims of sexual abuse. Giuffre has now dedicated her professional life to helping victims of sex trafficking. 26. On December 30, 2014, Giuffre…
…pursuant to Local Civil Rule 26.2(c). Ms. Giuffre objects to the requests in that they seek to invade her privacy for the sole purpose of harassing and intimidating Ms. Giuffre who was a minor victim of sexual trafficking. …
…substantial payout, directly from the Clinton Foundation to keep her quiet. She is 1000% certain that the FBI did a cover up and she has the individual names of Hilary’s Special Agent Officers involved in intimidating her. She was…