…by and through her undersigned counsel, hereby files this Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by…
…by and through her undersigned counsel, hereby files this Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by…
…by and through her undersigned counsel, hereby files this Supplement to her Motion for Adverse Inference Instruction Based on New Information. Eleven months into this case, and after the close of fact discovery, Defendant continues to refuse to abide by…
…Plaintiff, Ms. Giuffre, by and through her undersigned counsel hereby gives this Court notice of a related action, and states as follows. For many months, Ms. Giuffre has attempted to serve process on Defendant’s press agent, Ross Gow, who…
…Giuffre has diligently sought Mr. Gow’s deposition for months, and has been unsuccessful only because of his 1 Case 1:15-cv-07433-LAP Document 343 Filed 08/09/16 Page 2 of 8 efforts to frustrate and…
…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff then asked this Court to re-open discovery for the deposition of Ms. Ransome…
…Plaintiff, also counsel for non-party witness Sarah Ransome, in mid-January belatedly disclosed a “new witness” counsel apparently had known about for months.2 Plaintiff then asked this Court to re-open discovery for the deposition of Ms. Ransome…
…ex ecu ted a release and requ est for record s from over fou r months ago,on M ay 9,20 16.O n M ay 25,20 16,M s.Giu ffre prod u ced the requ estto …
…ready to pounce with voice recorders and cameras in hand. In recent months, journalists have searched high and low for Maxwell, who had already been maintaining a low profile even before the Epstein scandal came roaring back to life this…
…Act of 1990 requires the Administrative Office of the United States Courts to prepare a semiannual report summarizing judicial inaction, including motions pending more than six months and civil cases pending more than three years. See 28 U.S.C…
…so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 cell phone? 11 A. About eight months. 12 Q. What happened to it? 13 A. I got rid of it. 14 Q…
…so I 8 can't remember that number offhand. 9 Q. How long did you have that 10 cell phone? 11 A. About eight months. 12 Q. What happened to it? 13 A. I got rid of it. 14 Q…
…Yeah, this is three, four months down the 6 you contact any of my friends again did she say ,, 7 road. 7 anything else about what you know about Mr. 8 …
…one time. Appro~i~~~e;~ 5 t~~t~~~t~:ra~~~~~~e~a~ 0 a~~~~a~~:~ ~rii~kg!~~~~ advised she was in need to make some quick cash to make the rent that month . She agreed to go to the house. She had been told by …
…one time. Appro~i~~~e;~ 5 t~~t~~~t~:ra~~~~~~e~a~ 0 a~~~~a~~:~ ~rii~kg!~~~~ advised she was in need to make some quick cash to make the rent that month . She agreed to go to the house. She had been told by …
…yes. 15 time. 16 Q. How is it that you are currently 16 Q. Years ago, days ago, months ago? 17 supporting yourself? 17 A. It's been at least over a year. 18 A. I'm on disability. 18…
…expended considerable sums of money and considerable time to ensure Ms. Giuffre’s compliance with her discovery obligations. (DE 96 at 7.) Fact discovery closes in less than two months, and Defendant has yet to disclose information about what was…
…sue Epstein for damages, she was severely bullied and threatened by his lawyer Alan Dershowitz whom she also had sexual relations with and who was also heavily involved in Epstein's paedophile Ring. A couple months later, she was then…
…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 and psychiatric injuries…
…Yeah, this is three, four months down the 6 you contact any of my friends again did she say 7 road. 7 anything else about what you know about Mr. 8 Q. So if you left in -- 8 Epstein and…
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