…OVERVIEW 1. The charges set forth herein stem from the role of GHISLAINE MAXWELL, the defendant, in the sexual exploitation and abuse of multiple minor girls by Jeffrey Epstein. In particular, from at least in or about 1994, up to…
…Repeated Disregard for this Court’s Order Supports An Adverse Inference Ms. Giuffre does not want to burden the Court with unnecessary briefing on a topic that has been argued multiple times. See Docket Entry 96 (Motion for Forensic Examination)…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…For example, non-party Ransome witnessed the following: Q. And when you say you were on rotation, you mean you were having sex with Jeffrey multiple times per day? A. No. As when I was finished another girl was called…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…And for 8 the record, she is an absolute total liar and 9 you all know she lied on multiple things and 10 that is just one other disgusting thing she 11 added. 12 Q. Did you help her obtain…
…the Court’s order, Ms. Giuffre effected alternative service of a subpoena to testify at a deposition on Ms. Kellen in multiple ways, all calculated to give her actual notice of the subpoena. See Schultz Decl. at Composite Exhibit 1…
…terms “confidentiality agreements” and “associated entity” are vague, undefined and susceptible of multiple meanings and definitions Maxwell objects to this Request on the grounds that it is overly broad, unduly burdensome and/or propounded for the improper purpose of annoying…
…August 9, 2016, DE 352 at p. 1-2, Order directing Defendant to “capture all of the sent/received emails from Defendant’s multiple email accounts, including . . . any other email accounts Defendant has used in the past or currently uses…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…and Jeffrey. And for the record, she is an absolute total liar and you all know she lied on multiple things and that is just one other disgusting thing she added. (4/22/16 Tr. at 75-76). The Palm…
… ARGUMENT I. Ms. Maxwell’s Motion to Dismiss Provides “Good Cause” to Stay Discovery A. The Pending Motion Cites Multiple, Independent Grounds for Dismissal A stay of discovery is particularly appropriate where, as here, a pending motion to dismiss…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions. 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates. 18 Q Was it while you were still…
…Edwards and Cassell Waived Any Work Product Protection .......................................... 9 V. Edwards and Cassell are Conflicted Because of Their Multiple Roles – Plaintiff’s Choice to Present Their Testimony at Trial not Relevant to the Waiver Issue.............................. 10 CERTIFICATE OF SERVICE…
…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…
…her and Ms. Maxwell and Jeffrey 15 were all intimate together on multiple occasions . 16 Q When did she tell you this? 17 A I'm not exactly sure on the dates . 18 Q Was it while you were still…
…stay discovery pending resolution of her Motion to Dismiss. First, the Motion to Dismiss presents multiple, independent bases upon which this Court may dismiss the Complaint pursuant to Rule 12(b)(6). Each basis for dismissal is legally well-founded…
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