…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…clearly asked solely for the purpose of embarrassing, intimidating and harassing a non-party already fearful for her safety and life based upon the abuse she suffered at the hands of Defendant and Epstein, abuse as to which she testified…
…...........................................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…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…...........................................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…
…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…
…re 11 seeking information to be able 12 to -- the witness has already 13 expressed fear about her -- 14 people currently going after her. 15 So we would object to that 16 intimidation of a nonparty 17 witness. 18 Q…
…invade the privacy rights of a sex abuse victims (sic),” and “is meant for the improper purpose of harassing and intimidating this victim.” Then Plaintiff stated that “subject to the forgoing objections,” she is producing 3,190 documents and will…
…to Giuffre, they were not made in good faith anticipation of litigation, and instead were made for the inappropr iate purpose of "bul ly(ing] ," "harass]ment]," and "intimid[ation]." See Front, 28 N.E.3d at 19 (2015). According…
…seeks to invade the privacy rights of a sex abuse victims (sic),” “is meant for the improper purpose of harassing and intimidating this victim” or seeks “confidential financial information.” Then Plaintiff stated that “subject to the forgoing objections,” she is…
…Defendant’s intimation that there is an undisclosed account is directly beneath a heading that states: “There is no ‘Undisclosed’ Account.” 4 Case 1:15-cv-07433-LAP Document 1219-43 Filed 07/15/21 Page 5 of 12…