…that Jane Doe No. 3 suffered as a minor child, and Defendant’s threats and intimidation, it would be both unreasonable and oppressive to require this non-party to comply with this subpoena duces tecum. Accordingly, Defendant’s subpoena should…
…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…
…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…
…asserts, without factual or legal support, that her financial information is being sought “for the purpose of harassment and intimidation.” Because Ms. Ransome failed to address the relevance argument asserted by the Motion, this issue should be deemed admitted. Compare…
…sexual predator and his accomplices by bullying, harassing, intimidating and smearing child victims of rape. Unprecedented Impunity At first glance, Epstein's story reads like a typical case of two-tiered justice in America, where the wealthy and powerful are …
…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…
…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…
…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. …
…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…