…states as follows: INTRODUCTION Plaintiff comes to this Court – for the third time – seeking to reopen the deposition of Ms. Maxwell based on the production of two innocuous documents which she received more than two months ago on August 16…
…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, forthwith, to deliver any “materials” to the Defendant for the following reasons: For months Ms. Maxwell has been requesting documents from the Plaintiff relating to her claim that there is an ongoing and active criminal investigation in which Ms…
…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…
…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…
…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…
…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 …
…files this response to Jeffrey Epstein’s motion to quash a subpoena calling for his testimony. Having spent months attempting to avoid service of a subpoena, Epstein claims that it will now be an “undue burden” to answer questions at…
… They 22 have been working with her. They had been working on this 23 matter for many months now. We need them as counsel of record 24 in the case now because we are going to have depositions 25 throughout…
…this claim. As she now admits, Plaintiff only began to request her own medical records on April 5, 2016 – 15 months after the supposed defamation, 8 months after filing suit, 8 weeks after the defense requested the records, 2 weeks…
…Ghislaine Maxwell, March 2, 20161 Less than six months after representing to this Court that this case involves “highly personal and sensitive information” warranting a broad protective order, Defendant now wants to publicize police reports concerning Ms. Giuffre - most of…
…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…
…that addressing all remaining objections at once would be unduly burdensome. As an initial matter, the Court should deny Maxwell’s de facto application for a five-month stay, and require her to demonstrate good cause to justify any further…
…She also added details about her allegations that Epstein -- who served 13 months in jail after being convicted of soliciting a minor for sex in 2008 -- ordered her to have sex on three occasions with Prince Andrew in London at…
…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…
…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…
…01/05/24 Page 4 of 6 97 1 Q Was it earlier in the time you were with 2 her, or... 3 A It was about -- I'd say about six months 4 or so. I don't know…
…(DE 1.) Ms. Giuffre is seeking at least $50 million in compensatory and punitive damages from Ms. Maxwell. Just a few months after the suit was filed, on April 28, 2016, the New York Post reported that 2 As recently…
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