Found 33 results for “million” in 343ms

gov.uscourts.nysd.447706.1198.13_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.13_1 19 pg

…with Court Order and Failure to Comply with Rule 26(a) (“Response”), as follows: INTRODUCTION Plaintiff filed this Complaint in September 2015 seeking $30 million of non-economic damages related to her psychological damage from a defamation which, she claims…

gov.uscourts.nysd.447706.269.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.269.0 19 pg

…with Court Order and Failure to Comply with Rule 26(a) (“Response”), as follows: INTRODUCTION Plaintiff filed this Complaint in September 2015 seeking $30 million of non-economic damages related to her psychological damage from a defamation which, she claims…

gov.uscourts.nysd.447706.354.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.354.0 40 pg

…that Ms. Maxwell had subjected plaintiff to “sex trafficking” while Plaintiff was 15 years old. Plaintiff alleged in her Rule 26(a)(1)(A)(iii) disclosures that she has suffered noneconomic injury of “not less than” $30 million, medical expenses…

gov.uscourts.nysd.447706.996.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.996.0 14 pg

…about her alleged sexual encounters with ever more prominent men. Whenever anyone denies her allegations, she and her coterie of lawyers threaten to sue or sue for tens of millions of dollars for “defamation.” Mr. Dershowitz find himself, as Ms…

gov.uscourts.nysd.447706.132.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.132.1 31 pg

…13 time that she knew Mr. Epstein, and it certainly relates to all 14 of her requests for, I believe she has requested $30 million in 15 damages, your Honor, not just from the defamation, but also 16 harkening back…

gov.uscourts.nysd.447706.1219.30.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.30 16 pg

…Ms. Maxwell should have to provide the same information. Of course, Plaintiff seeks over $80 Million dollars in compensatory damages based on her alleged loss of reputation and emotional distress, putting her personal financial information directly at issue. Ms. Maxwell…

gov.uscourts.nysd.447706.64.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.64.0 14 pg

…as Ex. B. to the Menninger Decl. Each of those figures and particularly the fantastical $5 million, $30 million and $50 million “estimates” are completely unsupported. Four months later, Plaintiff’s supplemented disclosures state that she suffered: (A) “Physical, psychological…

gov.uscourts.nysd.447706.63.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.63.0 22 pg

…her prior wages (if any), her bases for claiming $30 million in non-economic damages. Plaintiff has admitted that some of the treating professionals she will be relying on live in Australia but said she couldn’t understand why we…

gov.uscourts.nysd.447706.1354.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1354.0 7 pg

…Earlier today, the DOJ released an additional three million pages of Epstein-related records. 4 Maxwell’s counsel asserts that many John Does “relied” on the Protective Order (Dkt. 62) in this case and therefore require an opportunity to object…

gov.uscourts.nysd.447706.1331.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.12 10 pg

…of resources, but as this Court is aware, Defendant is a wealthy socialite (wbo recently sold her New York Townhome for $15 million dollars) who has heavily litigated this case in ways that were completely unnecessary. 2 Moreover, deposition discovery…

gov.uscourts.nysd.447706.849.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.849.0 94 pg

…in his review. The alleged unique users, 6 which is his phrase for somebody who went on a website 7 somewhere, is more than 10 million more, and the other number, 8 which is the number of publications, has also…

gov.uscourts.nysd.447706.1218.40.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.40 30 pg

…13 time that she knew Mr. Epstein, and it certainly relates to all 14 of her requests for, I believe she has requested $30 million in 15 damages, your Honor, not just from the defamation, but also 16 harkening back…

gov.uscourts.nysd.447706.847.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.847.0 94 pg

…in his review. The alleged unique users, 6 which is his phrase for somebody who went on a website 7 somewhere, is more than 10 million more, and the other number, 8 which is the number of publications, has also…

gov.uscourts.nysd.447706.235.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.235.1 31 pg

…13 time that she knew Mr. Epstein, and it certainly relates to all 14 of her requests for, I believe she has requested $30 million in 15 damages, your Honor, not just from the defamation, but also 16 harkening back…

gov.uscourts.nysd.447706.136.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.136.0_2 29 pg

…13 time that she knew Mr. Epstein, and it certainly relates to all 14 of her requests for, I believe she has requested $30 million in 15 damages, your Honor, not just from the defamation, but also 16 harkening back…

gov.uscourts.nysd.447706.1218.49.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.49 27 pg

…This allegation, and the string of inferences necessary to make it “work,” is patently absurd. Millions of people were present in the New York City area when Ms. Giuffre travelled there; it is simply not reasonable to infer from my…

gov.uscourts.nysd.447706.1307.4.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1307.4 28 pg

…burden must take into account the scope of the underlying case. Ms. Giuffre is seeking both compensatory and punitive damages that would total millions of dollars. Against that backdrop, a handful of additional depositions cannot be seen as unduly burdensome…

gov.uscourts.nysd.447706.1218.26.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.26 4 pg

…has another book to flog. TIDBITS It’s official. Daytime talker Rosie O’Donnell will be a celeb contestant on ABC’s Who Wants to Be a Millionaire. O’Donnell, who was a ``phone-a-friend’’ on an earlier show…

gov.uscourts.nysd.447706.1320.24.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.24 16 pg

…of evidence: depositions are needed. Third, the burden and expense of this proposed discovery is limited to three additional depositions. Defendant in this case is a multi-millionaire with able counsel. Three depositions will not cause her undue burden, expense…

gov.uscourts.nysd.447706.1137.17_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.17_1 16 pg

…evidence: depositions ar e needed. Third, the bmden and expense of this proposed discovery is limited to three additional depositions. Defendant in this case is a multi-millionaire with able counsel. Three depositions will not cause her undue bmden, expense…

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