…COMMANDED lo permit entry on to the designated premises, land, or other property possessed or contro l led by you at the l ime, date, and location set forth below. so Lhal lhc ,·cquesling party rnay inspect, measure, survey, photograph…
…with Prince Andrew. Plaintiff was well paid for this picture, and continued to get royalties on the reprints. Despite multiple requests, Plaintiff has not been able to produce or provide the actual native version of the picture, or identify the…
…Can you please 13 answer the question. 14 MR. GUIRGUIS: I'm 15 instructing the witness not to 16 answer questions regarding 17 current information about her own 18 location, her family's location, 19 things of that nature. 20 …
…Can you please 13 answer the question. 14 MR. GUIRGUIS: I'm 15 instructing the witness not to 16 answer questions regarding 17 current information about her own 18 location, her family's location, 19 things of that nature. 20 …
…for the subpoenaing party. 2. This Request calls for the production of all responsive Documents in your possession, custody or control without regard to the physical location of such documents. 3. If any Document was in your possession or control…
…responsive Documents in your possession, custody or control without regard to the physical location of such documents. 3 Case 1:15-cv-07433-RWS Document 17-1 Filed 12/01/15 Page 4 of 13 3. If any Document…
…2. This Request calls for the production of all responsive Documents in Your possession, custody or control without regard to the physical location of such documents. 3. If any Document requested was in any defendant’s possession or control, but…
…Document. 3. This Request calls for the production of all responsive Documents in your possession, custody or control without regard to the physical location of such documents. 4. If any Document requested was in your possession or control, but is…
…agent, Ross Gow, who is a key witness in this case because he issued, on Defendant’s behalf, one of the defamatory statements at issue to multiple media outlets. Defendant’s counsel, Philip Barden, is also counsel for Mr. Gow…
…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…
…to documents that may be released, they should not receive a second opportunity to object thereafter. Allowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process. The same is true of…
…that you use "wildcards" to ensure that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by "replacing" single or multiple characters.) Where there are a specific number of characters needed to be included…
…also a key topic in this litigation: Defendant’s defamation of Ms. Giuffre through the media. Multiple documents show Epstein’s involvement in crafting Defendant’s various draft statements to the media concerning Ms. Giuffre, and one of the late …
…that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by “replacing” single or multiple characters.) Where there are a specific number of characters needed to be included, a single wildcard will achieve that…
… 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…
…that you use "wildcards" to ensure that embedded terms are located. (Wildcard characters are used to expand word searches into pattern searches by "replacing" single or multiple characters.) Where there are a specific number of characters needed to be included…
…that Ms. Giuffre has lost access to her Hotmail.com account (multiple password 1 Case 1:15-cv-07433-RWS Document 207 Filed 06/13/16 Page 2 of 7 recovery attempts failed due to the aged, non-recoverable…
…not have had a working understanding of the process in the first place.1 Ms. Giuffre argues that “[a]llowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process.” (Dkt. no…
…Giuffre has suffered prejudice, and will continue to suffer prejudice, due to Defendant’s non-compliance with her discovery obligations and non-compliance with this Court’s Order, for multiple reasons. First, this Court granted Ms. Giuffre’s Motion to…
… Yeah, we -- yeah. He was 3 really intimate all the time. We 4 had -- multiple times. I can't tell 5 you how many times I've slept with 6 Jeffrey. I mean, we were on rotation. 7 Every single…
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