…to address, their (1) preservation obligations, (2) search and review protocols, and (3) sources of ESI production. Under this model order, the parties are required to discuss methods for search and review, including potential keyword searches, date restrictions, and search…
…severe and extensive sexual abuse. See Ex. A, ¶¶ 40-114. Epstein and his associates lured these girls and young women to his island with promises of modeling and other career opportunities. Id., ¶ 49. Once they arrived, though, they were sexually…
…just pleasing these men and keeping Ghislaine and 13 Jeffrey happy. Their whole entire lives revolved 14 around sex. 15 They call massages sex. They call 16 modeling sex. They call 17 Q I asked you the names for people. …
…Claims ................................................. 7 F. Request 18: Driver’s License .............................................................................................. 8 G. Request 19-20: Education Records ..................................................................................... 9 H. Request 21-22: <…
…Claims ................................................. 7 F. Request 18: Driver’s License .............................................................................................. 8 G. Request 19-20: Education Records ..................................................................................... 9 H. Request 21-22: <…
…27 Kate bares all: Moss poses naked in her …
…2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had…
…2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had…
…t q e CPU s hardware sitting on floor next to a glass type desk. The CPU had no discernable identifiers or features indicating a make or model. This CPU was powered off with the power cord not plugged in …
…2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had…
…P. 37(a)(3)................................................................................................................... 6 Other Authorities ABA Model Rules of Professional Conduct Rule 1.6(a)................................................................ 9 …
… 10 A. It wasn't candid photos. They were all, 11 like, staged. 12 Q. Like a model? 13 A. Yes. And my -- I don't recall necessarily 14 knowing any of the people in those photos. I 15 remember…
…2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had…
…to the preliminary conference, their (1) preservation obligations, (2) search and review protocols, and (3) sources of ESI production. Under this model order, the parties are required to discuss methods for search and review, including potential keyword searches, date restrictions…
…2 Q. Did Ghislaine ever describe to you what 3 types of girls Jeffrey liked? 4 A. Model types. 5 Q. Did Ghislaine ever talk to you about how 6 you should act around Jeffrey? 7 A. She just had…
…Civ. P. 37(a)(3)................................................................................................................... 6 Other Authorities ABA Model Rules of Professional Conduct Rule 1.6(a)................................................................ 9 …
…witness. She refused to answer basic questions such as her then current address (3.24.2010 Tr. at 10); and what company she worked for as a model (id. at 97). There is no inference to be drawn from the…
…Tr. at 171-172, 179-180. Request 21 – Ms. Ransome testified she did very little modeling because she wasn’t successful at it and has no documents relating to her modeling) See Pottinger Dec. at Exhibit 1, Ransome Tr…
…Tr. at 171-172, 179-180. Request 21 – Ms. Ransome testified she did very little modeling because she wasn’t successful at it and has no documents relating to her modeling) See Pottinger Dec. at Exhibit 1, Ransome Tr…
…the years 2005-present. 11. All Documents referencing any commercial plane tickets, boarding passes, or any other mode of travel during the time period 2006-2007. 12. Any credit card receipt, canceled check, or any other Document reflecting travel by…
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