Found 78 results for “months” in 222ms

gov.uscourts.nysd.447706.363.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.9 5 pg

…in Judge Freeh’s professional opinion, “The totality of the evidence found during the investigation refutes the allegations made against Professor Dershowitz.” STATEMENT OF LOUIS J. FREEH Over the past several months, an independent investigation was conducted, under my supervision…

gov.uscourts.nysd.447706.962.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.962.0 7 pg

…Order. INTRODUCTION The Protective Order requires the destruction or return of all “Confidential”-designated materials. This action was terminated more than eighteen months ago when the parties reached a settlement and stipulated to dismissal, and the Court dismissed the case…

gov.uscourts.nysd.447706.34.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.34.2 3 pg

…opportunities. • See who you know in common • Get introduced • Contact Ross directly Experience Owner, Managing Partner ACUITY Reputation January 2010 – Present (6 years 2 months) ACUITY advises Governments, Corporates and UHNWIs on reputational issues Skills Public Relations Marketing …

gov.uscourts.nysd.447706.363.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.11 40 pg

…client’s allegations that Dershowitz had sexual relations with her when she was a minor. Settlement talks in the defamation case have been going on for months, and the two sides just reached agreement. Shortly before 5 p.m. today…

gov.uscourts.nysd.447706.751.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.751.12 3 pg

…before returning with cash. He did say that she tried to get out of the sex business, but was dragged back in. Last month it was revealed Roberts accused two male acquaintances she was raped, bringing her credibility into 1…

gov.uscourts.nysd.447706.1078.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.5 161 pg

…Case 1:15-cv-07433-LAP Document 1078-5 Filed 07/29/20 Page 8 of 161 It raises serious questions as to why Maxwell, whose whereabouts have been a mystery for months, has never been charged with any wrongdoing…

gov.uscourts.nysd.447706.1227.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1227.0 2 pg

…1226 at 2, 3. As Plaintiff clearly laid out in a letter submitted to the Court nine months ago, because the Court is currently proceeding through the unsealing process on a Doe-by-Doe basis, the Original Parties’ understanding is…

gov.uscourts.nysd.447706.1256.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.12 32 pg

…In fact, for the most part, her failures to actively pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…

gov.uscourts.nysd.447706.89.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.89.0 10 pg

…admission pro hac vice appear to be inaccurate, this consolidated reply is being filed to clarify a few points of law and fact. II. ARGUMENT For many months now, Professor Cassell and Mr. Edwards have actively worked to help represent…

gov.uscourts.nysd.447706.1328.43.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.43 8 pg

…pick those names, were 5 Mr. Rodriguez stated he was employed by Jeffrey 5 they associated with Mr. Epstein? 6 Epstein for approximately six months. 6 A. Yes. 7 I think we already talked about that. 7 Q. And what…

gov.uscourts.nysd.447706.1161.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1161.0_1 17 pg

…id. ¶¶ 5(a)-(h)). The protective order has been a primary theater of battle in this litigation over the past several months.1 Most notably, it has been the subject of two separate requests seeking modification brought by Alan Dershowitz…

gov.uscourts.nysd.447706.1328.31.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.31 13 pg

…agreement among them, but she refuses to disclose the joint defense agreement, and this Court, months ago, has already ordered Defendant to turn over her communications with Epstein and Dershowitz that she purported were privileged. (See April 15, 2016 Order…

gov.uscourts.nysd.447706.408.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.408.0 13 pg

…2014, despite having had four months to provide a position, the Government responded by email to counsel that it was seeking more time, indicating that the Government understood that victims’ counsel might need to file a motion with the court…

gov.uscourts.nysd.447706.148.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.148.0 9 pg

…ARGUMENT I. PLAINTIFF’S VIOLATION OF THIS COURT’S ORDER TO PRODUCE DOCUMENTS IS NOT AN OPPORTUNITY FOR HER TO RE-LITIGATE THE ISSUE. Plaintiff has been attempting to dodge the production of these documents for months. First, Plaintiff claimed…

gov.uscourts.nysd.447706.1219.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.11 13 pg

…agreement among them, but she refuses to disclose the joint defense agreement, and this Court, months ago, has already ordered Defendant to turn over her communications with Epstein and Dershowitz that she purported were privileged. (See April 15, 2016 Order…

gov.uscourts.nysd.447706.102.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.102.0 9 pg

…projected trial date in the fall, while Defendant has repeatedly attempted to stall progress1. Defendant’s deposition is currently set to be taken on Friday, April 22 – many months after Ms. Giuffre filed her complaint. Defendant’s deposition has not…

gov.uscourts.nysd.447706.1332.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.11 9 pg

…it failed to list verbatim any such allegedly unanswered discovery request, as required by local rule. Additionally, discovery closed nearly eight months ago, and trial is 60 days away. Substantively, the Motion to Compel is facially frivolous. It argues Mr…

gov.uscourts.nysd.447706.35.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.35.0 31 pg

…production of documents on defendant on October 27, 2015. Now, almost four (4) months later, and even after this Court denied defendant’s attempts to stay discovery and directed a response, defendant is still refusing to produce highly relevant documents…

gov.uscourts.nysd.447706.1320.28.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.28 32 pg

…In fact, for the most part, her failures to actively pursue depositions with these witnesses qualifies as in-excusable neglect: She frittered away seven of the eight months of the discovery period and now has placed Ms. Maxwell, this Court…

gov.uscourts.nysd.447706.1320.18.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.18 40 pg

…about whether Dershowitz had been involved with massages by young girls; x refusals by Jeffrey Epstein to discuss Dershowitz’s involvement but instead to invoke his Fifth Amendment right. - Id. at 26-38. Several months later, on April 7, 2015…

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