…Laura, I write pursuant to this Court' s June 20, 2016, Order regarding search and production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from…
…Defendant. ________________________________/ MS. GIUFFRE’S NOTICE OF FILING RESPONSE TO PROPOSED INTERVENER MICHAEL CERNOVICH D/B/A CERNOVICH MEDIA’S OPPOSITION TO NOTICE OF PLAINTIFF’S PROPOSED REDACTIONS TO THIS COURT’S ORDER DENYING SUMMARY …
…agent, Ross Gow, who is a key witness in this case because he issued, on Defendant’s behalf, one of the defamatory statements at issue to multiple media outlets. Defendant’s counsel, Philip Barden, is also counsel for Mr. Gow…
…Laura, I write pursuant to this Court's June 20, 2016, Order regarding search and production from Defendant's electronic media. Accordingly, please use IMAP Capable software (or a functional equivalent) to capture all of the sent/received emails from…
…concerning Plaintiff’s medical and mental health treatment, (b) her unjustifiable refusal to answer questions related to statements the media “got wrong,” (c) material edits to her deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed…
…19-20: Education Records ..................................................................................... 9 H. Request 21-22: Modeling Contracts ................................................................................... 9 I. Request 30: Social Media ........................................................…
…19-20: Education Records ..................................................................................... 9 H. Request 21-22: Modeling Contracts ................................................................................... 9 I. Request 30: Social Media ........................................................…
…Gow is a key witness in this case, given that he was authorized by the Defendant to release the defamatory statements, that are central to this case to the media. Defendant, however, attempts to block his deposition by suggesting that…
…factually unsupported statements, an additional explanation about who is requesting the unsealing of sealed materials, i.e., the media, gives Non-Parties accurate and important information to help inform their decision whether to participate. In other words, it is one…
…girls who alleged sexual abuse by Epstein and others in his circle. Giuffre alleged that Epstein's ex-girlfriend Ghislaine Maxwell, daughter of the late media tycoon Robert Maxwell, abused her. Ghislaine Maxwell has denied allegations of enabling abuse. Epstein…
…concerning Plaintiff’s medical and mental health treatment, (b) her unjustifiable refusal to answer questions related to statements the media “got wrong,” (c) material edits to her deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed…
…Alan M. Dershowitz. 9. All documents concerning any communications by you or on your behalf with any media outlet concerning Alan M. Dershowitz or the Federal Action, whether or not such communications were “on the record” or “off the record…
… Identify any email address, email account, cellphone number and cellphone provider, social media account and login or screen name, text or instant messaging account name and number, that You have used, applied for or been supplied between 1998 and the…
…the materials are made publicly available, the media entities who have sought the unsealing will gain access to these materials including your name and the other references to you contained in the Sealed Materials, and they will be free thereafter…
…the account let alone the password. 3 By contrast, Ms. Maxwell requested that Plaintiff identify all email and social media accounts which she had used since 1998. Plaintiff provided false information, and purposefully omitted accounts that have since been discovered…
…Instead, Dershowitz make clear that his purpose is to advance his own agenda, and continue to wage his media war on Ms. Giuffre, as he has already appeared on national news calling her a “prostitute” and a “bad mother.”1…
…discovery only after resolution of dispositive motions, and some afford only disclosure of a financial affidavit prior to dispositive motions. See, e g., Hazeldine v. Beverage Media, Ltd., No. 94 CIV. 3466 (CSH), 1997 WL 362229, at *2-*3 (S…
… Identify any email address, email account, cellphone number and cellphone provider, social media account and login or screen name, text or instant messaging account name and number, that You have used, applied for or been supplied between 1998 and the…
…5 Q. -- about your experience? 6 You have to wait for me to 7 finish my question. 8 Have you had any agreements 9 with your lawyers about media rights 10 in any form? 11 MR. GUIRGUIS: Objection to 12…
…ties and is 'part of a very large and close family'. He said: 'Our client is not Jeffrey Epstein, and she has been the target of endless media spin', leading prosecutor Moe to later shoot back: 'These are the facts…