…either that there is or that there is not a pending criminal investigation of Ms. Maxwell. As for the Non-Prosecution Agreement involving Jeffrey Epstein, my only representation was that the name Ghislaine Maxwell does not appear in that document…
…by the police from Epstein’s home, and turned over to the Palm Beach County State Attorney as part of - the investigation and prosecution of Epstein. M Ghislaine Maxwell See (DE 280-2), Palm Beach County State Attorney’s Office…
…Ms. McCawley, on April 11, 2016, filed a pleading in Broward County, Florida court captioned: “Plaintiffs and Non-Party Virginia Giuffre’s Notice Regarding the Parties’ Joint Stipulation of Dismissal.” Menninger Decl. at Ex. B. In that pleading, Messrs. Cassell…
…of New York Virginia L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ MOTION FOR PROTECTIVE ORDER FOR NON-PARTY WITNESS Non-party Sarah Ransome, by and through her undersigned counsel,…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ______________________________/ NON-REDACTED DECLARATION OF SIGRID S. McCAWLEY IN SUPPORT OF PLAINTIFF’S MOTION TO EXCEED PRESUMPTIVE TEN DEPOSITION LIMIT IN FEDERAL RULE OF CIVIL PROCEDURE 30(A)(2…
… Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ MOTION FOR PROTECTIVE ORDER FOR NON-PARTY WITNESS PAGES 1-7 FILE UNDER SEAL Case 1:15-cv-07433-RWS Document 640 Filed 02/22/17 Page 2 of…
…Ms. Maxwell has access. Based on those searches, not one single additional responsive and non-privileged document has been identified. Ms. Maxwell’s original search for responsive documents was complete at the time it was conducted in February 2016. The…
…30, 2020 Honorable Loretta A. Preska United States District Court Southern District of New York 500 Pearl Street New York, NY 10007 Re: Defendant Maxwell’s Letter Submitting Materials Relating to Protocol and Non-Party Notice Giuffre v. Maxwell, No…
…Ms. Maxwell has access. Based on those searches, not one single additional responsive and non-privileged document has been identified. Ms. Maxwell’s original search for responsive documents was complete at the time it was conducted in February 2016. The…
…and I appear in this case as counsel for: Non-Party Jeffrey Epstein Date: 06/16/2016 --=~="-~-- ~tA·tJ~5~. • Attorney's signature …
…public statements made by Ms. Maxwell (RFP 17-18). Again, Ms. Maxwell and her counsel conducted a thorough search and produced any responsive non-privileged documents. To date, Ms. Maxwell has produced 1,130 pages of documents. Litigation concerning whether…
…Mccawley, Esq. Florida Bar No. 129305 --- ---- ; …
…public statements made by Ms. Maxwell (RFP 17-18). Again, Ms. Maxwell and her counsel conducted a thorough search and produced any responsive non-privileged documents. To date, Ms. Maxwell has produced 1,130 pages of documents. Litigation concerning whether…
…ments relatingto employment.A d d itionally,M s.Giu ffre has sentrequ ests forrecord s and releases to every employer(and even one non-employer)requ ested by D efend ant. For ex ample,u pon D efend ant…
…terramar email address for otherwise responsive documents, this search term would pull up thousands of documents related to her work for that organization which are (a) non-responsive and (b) irrelevant to this action. We will not agree to this…
…terramar email address for otherwise responsive documents, this search term would pull up thousands of documents related to her work for that organization which are (a) non-responsive and (b) irrelevant to this action. We will not agree to this…
…to award a large amount in damages even if you believe the damages are significant and may warrant such an award? NON-ECONOMIC DAMAGES/PAIN AND SUFFERING Who has heard of damages for pain and suffering or mental anguish? …