gov.uscourts.nysd.447706.22.0.pdf PDF
…DISTRICT OF NEW YORK Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. REPLY MEMORANDUM OF LAW IN SUPPORT OF DEFENDANT’S MOTION FOR A STAY OF DISCOVERY …
Found 19 results
for “memo”
in 268ms
gov.uscourts.nysd.447706.45.0.pdf PDF
…YORK --------------------------------------------------X .... ........................................... VIRGINIA L. GIUFFRE, Plaintiff, v. …
gov.uscourts.nysd.447706.59.0.pdf PDF
…York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. _________________________/ MEMORANDUM OF LAW IN SUPPORT OF PLAINTIFF’S MOTION FOR LEAVE TO SERVE ROLLING PRODUCTION AND PRIVILEGE LOG Plaintiff,…
gov.uscourts.nysd.447706.53.0.pdf PDF
…v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL MEMORANDUM OF LAW IN RESPONSE TO PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTIONS …
gov.uscourts.nysd.447706.17.1.pdf PDF
… “Correspondence” or “communication” shall mean all written or verbal communications, by any and all methods, including without limitation, letters, memoranda, and/or electronic mail, by which information, in whatever form, is stored, transmitted or 1 …
gov.uscourts.nysd.447706.1307.4.pdf PDF
…the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. As a result of Defendant’s inability to remember events, a variety…
gov.uscourts.nysd.447706.1320.10.pdf PDF
…the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. As a result of Defendant’s inability to remember events, a variety…
gov.uscourts.nysd.447706.1137.12_2.pdf PDF
…the Fifth. Instead, she testified that she suffered from a series of memo1y lapses and could not recall many of the key issues in dispute in this case. As a result of Defendant's inability to remember events, a variety…
1320-10.pdf PDF
…the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. As a result of Defendant’s inability to remember events, a variety…
gov.uscourts.nysd.447706.1328.2.pdf PDF
…1:15-cv-07433-LAP Document 1328-2 Filed 01/05/24 Page 25 of 26 Page 303 1 JOSEPH RECAREY - CONFIDENTIAL 2 went to New York but on a commercial flight. Does 3 that jog your memory? 4 MS…
gov.uscourts.nysd.447706.1325.17.pdf PDF
…grade? 21 A Yeah. It was during the day, though. I 22 have no clue about night school. 23 Q Got it. 24 But you do have a memory about Survivors 25 Charter School? Southern Reporting Company (386)257-3663
gov.uscourts.nysd.447706.1327.29.pdf PDF
…6 A. I think it was just she and I. I forgot 7 about that. Thank you for that memory. 8 Q. It's my job. 9 Anything else you remember about that day 10 in New York? 11 A. …
gov.uscourts.nysd.447706.1256.3.pdf PDF
…Court. Nonetheless, this case presents numerous challenges that require that she take more than ten depositions – not the least of which is Defendant’s extraordinary lack of memory about many events that would appear to have indisputably taken place. Ms…
gov.uscourts.nysd.447706.1328.23.pdf PDF
…14 Case 1:15-cv-07433-LAP Document 1328-23 Filed 01/05/24 Page 15 of 22 Further proof of malice comes from Defendant’s extraordinary lack of memory about her involvement in the abuse.11 For instance…
gov.uscourts.nysd.447706.1330.15.pdf PDF
…Defendant did not take the Fifth. Instead, she testified that she suffered from a series of memory lapses and could not recall many of the key issues in dispute in this case. For example, at her deposition, Defendant indicated that…
gov.uscourts.nysd.447706.1327.28.pdf PDF
…I already said I don't recall all 7 first met her? 7 the times I've seen her and I have no memory 8 A. I don't remember what she looked 8 of that. 9 like at the…
1320-30.pdf PDF
…Q What is the date the photograph was 11 printed? 12 A I believe it's in March 2001. 13 Q Okay. 14 A But that's just off of my photographic 15 memory. I don't -- it could be…
gov.uscourts.nysd.447706.755.0.pdf PDF
… The defendant was deposed about that, and 25 once again, her memory failed her. She has no memory SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 H39YGIUC Case 1:15-cv-07433-LAP Document 755 Filed 03/20/17…
gov.uscourts.nysd.447706.1320.30.pdf PDF
…Q What is the date the photograph was 11 printed? 12 A I believe it's in March 2001. 13 Q Okay. 14 A But that's just off of my photographic 15 memory. I don't -- it could be…
Comments