…to her (RFP 27), her employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016…
…to her (RFP 27), her employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016…
…which are witness names broken up into first and last names from your Rule 26 list, relate to your RFP number 5 (“All documents relating to massages…”). I represented to you that I have searched for the terms “massage,”…
…18 friend. During the interviews, Ms. Maxwell was 19 involved in seeking girls to perform massages 20 and work at Epstein's home. 21 MR. PAGLIUCA: Object to form and 22 foundation. 23 BY MR. EDWARDS: 24 Q. Did you…
…2, 3, 4, 6, 17, 32 and 37) x documents relating to various topics include massages (RFP 5 and 29), travel records (RFPs 8, 9, 14 and 39), a civil deposition in 2010 (RFP 19), and Ms. Maxwell’s professional…
…the kitchen were searched and yielded negative results . Th~ kitchen was searched and taken into evidence was a phone message book: that was located near a house phone. North of the kitchen was an office room which contained a computer…
…the kitchen were searched and yielded negative results . Th~ kitchen was searched and taken into evidence was a phone message book: that was located near a house phone. North of the kitchen was an office room which contained a computer…
…so . . . 8 BY MS. MCCAWLEY: 9 Q. How many massages did Jeffrey receive on 10 average in a given day? 11 MS. MENNINGER: Objection, foundation . 12 THE WITNESS: Three a day. 13 BY MS McCAWLEY: 14 Q. Let me back…
…allT erram arem ailsforotherw iseresponsivedocum entsasw ell . 3.W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I represented toyou thatIhavesearchedfortheterm s“ m assage…
…Giuffre] is telling the truth.” Defendant’s Response at 5. Defendant’s characterization is untrue.1 But, as the mere 1 Defendant wholly mischaracterized Ms. Sjoberg’s testimony as involving “professional massages.” Defendant’s Resp. at 5. In fact, Ms…
…Giuffre] is telling the truth.” Defendant’s Response at 5. Defendant’s characterization is untrue.1 But, as the mere 1 Defendant wholly mischaracterized Ms. Sjoberg’s testimony as involving “professional massages.” Defendant’s Resp. at 5. In fact, Ms…
…the kitchen were searched and yielded negative results . Th~ kitchen was searched and taken into evidence was a phone message book: that was located near a house phone. North of the kitchen was an office room which contained a computer…
…to her (RFP 27), her employment (RFP 28), and any person to whom she gave a massage (RFP 29). Ms. Maxwell conducted a thorough search of her email systems and her devices prior to her production on February 8, 2016…
…allT erram arem ailsforotherw iseresponsivedocum entsasw ellas . 3.W itnessnam es– You believethatsearchterm s124-341,w hicharew itnessnam esbrokenupintofirstand last nam esfrom yourR ule26 list,relatetoyourR FP num ber5 (“ Alldocum entsrelatingtom assages… ” ).I represented toyou thatIhavesearchedfortheterm s“ m assage…
…Maxwell kept the 20 MR. CRITTON: Form to the last question, 20 names and telephone numbers of the girls who came 21 move to strike the answer as nonresponsive. 21 to do massages? 22 BY MS. EZELL: 22 A. Yes…
…MS. SCHULTZ: Object to form. 3 THE WITNESS: Correct. 4 BY MR. PAGLIUCA: 5 Q. And none of them ever claimed to have been 6 sent to another location to give another man a 7 massage, correct? 8 MS. SCHULTZ…
…time, where she was going to meet with and Epstein. They went for a bike ride, but had a 9 massage, which Epstein walked in on while she was getting a massage. He asked her to turn over, expose…
…telephone, telecopies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. "Defendant" shall mean the ddendant Ghislaine Maxwell and her employees, representatives or agenls. 4. "Document" shall mean all v.:rit:ten and graphic matter…
…lelecopies, c-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. "Plaintiff" in the above captioned action shall mean the plaintiff Virginia Giuffre formerly known as Virginia Roberts. 4. "Defendant" in the above captioned action shall…
…by telephone, telecopies, e-mail, text, modem transmission, computer generated message, mail, personal delivery or otherwise. 3. “Defendant” shall mean the defendant Ghislaine Maxwell and her employees, representatives or agents. 4. “Document” shall mean all written and graphic matter, however…