…Evidence ........................................................................................................... 2 C. Ms. Maxwell Already Has Fully Responded to All Discovery Requests Relating to Payments Made to Her By Epstein ...................................................................................... 5 …
…Richards. 4. All Docume nts containing communications with law enforcement agency concerning Virginia Roberts. 5. All Documents reflecting any payment of any money to Virginia Roberts. 6. All Documents reflecting any contract …
…Ferrante, No. 13 CIV 4468 VEC, 2014 WL 1327968 (S.D.N.Y. Apr. 3, 2014) .........................................9 In re Payment Card Interchange Fee & Merch. Dis., No. MD-05-1720 (JG)(JO), 2007 WL 121426 (E.D.N.Y. Jan. 12…
…cross examination, not one. Any standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein…
…of Sigrid McCawley at Composite Exhibit 9, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. Ms. Giuffre proposes that she be permitted to serve her deposition notices by means other than personal service…
…Page 10 of 11 15. All Documents reflecting any money, payment, valuable consideration or other remuneration re.ceived by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey Epst.ein. 16. All bank statements…
…to her sexual abuse and defamation. Indeed, Ms. Giuffre is actively seeking information from her medical providers and has made payment to obtain those records. Additionally, Ms. Giuffre has disclosed the names and addresses of both physicians. See McCawley Decl…
…members. (Complaint ¶ 53) 15. All Documents reflecting any money, payment, valuable consideration or other remuneration received by You from Jeffrey Epstein or any person known by You to be affiliated with Jeffrey Epstein. 16. All bank statements, credit card statements…
…default judgment against the disobedient party; or (vii) treating as contempt of court the failure to obey any order except an order to submit to a physical or mental examination. (C) Payment of Expenses. Instead of or in addition to…
… b. The known addresses and telephone numbers of disclosed individuals including the Plaintiff; and c. Order payment, under Fed.R.Civ. P. 37(c)(1) of reasonable expenses including attorney fees required to prosecute this Motion because of Plaintiff’s…
…default judgment against the disobedient party; or (vii) treating as contempt of court the failure to obey any order except an order to submit to a physical or mental examination. (C) Payment of Expenses. Instead of or in addition to…
…See Decl. of Sigrid McCawley at Composite Exhibit 8, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. Simply put, given the mountain of evidence proving that the Defendant was heavily involved in Epstein…
…of Sigrid McCawley at Composite Exhibit 9, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. Ms. Giuffre proposes that she be permitted to serve her deposition notices by means other than personal service…
…default judgment against the disobedient party; or (vii) treating as contempt of court the failure to obey any order except an order to submit to a physical or mental examination. (C) Payment of Expenses. Instead of or in addition to…
…cross examination, not one. Any standard of truth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. One firm created and sold fake cases against Mr. Epstein…
…only proper adverse inference. Plaintiff previously sued Mr. Epstein for the conduct about which he refused to answer in his deposition. As a result of that lawsuit Plaintiff received a $500,000 settlement payment from Mr. Epstein, a matter about…
…of Sigrid McCawley at Composite Exhibit 9, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. Ms. Giuffre proposes that she be permitted to serve her deposition notices by means other than personal service…
…Any standard of trnth and were used for those who claimed they were victims to receive financial payment to be shared between them and their lawyers. Need I say more. fihese so called 'new revelations' stem from an alleged dia1y…
…Ms. Giuffre at this time. 1 Ms. Giuffre escaped.4 Therefore, discovery requests concerning Defendant’s continued trafficking of minors, and continued contact with her co-conspirators (including payments from Epstein), are relevant and discoverable. II. ARGUMENT …
…See McCawley Decl. at Exhibit 1, Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article with photograph. 2 Case 1:15-cv-07433-LAP Document 102 Filed 04/19/16 Page 3 of…
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