…Ms. Giuffre objects to this information in that any payment information for the sexual trafficking she endured at the hands of Jeffrey Epstein and Ghislaine Maxwell is in the possession, custody and control of the Defendant and Jeffrey Epstein. 11…
…Earning Capacity...................19 10. Ms. Giuffre Has Provided All Documents Concerning “Selling Information” And Payments Received By The Media....................................20 11. This Court Has Ruled That Ms. Giuffre Is Not Required To Answer …
…Chelsea Clinton’s wedding in Rhinebeck, New York. See McCawley Decl. at Composite Exhibit 8 Maxwell Deposition Notice; Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article with photograph. In 2011, Maxwell started issuing press statements through…
…Ms. Giuffre objects to this information in that any payment information for the sexual trafficking she endured at the hands of Jeffrey Epstein and Ghislaine Maxwell is in the possession, custody and control of the Defendant and Jeffrey Epstein. 11…
…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…
…all documents concerning any apartment or other dwelling occupied by Plaintiff from 1999 to the present, including but not limited to, all documents concerning the acquisition of, and payment for, such dwellings. This Request includes, but is not limited to…
…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…
…sought, and received, Ms. Giuffre’s personal financial information. Specifically, she sought any payment information relating to the media. See Defendant’s First Set of Requests for Production at No. 30. Ms. Giuffre provided documents responsive to this request, which…
…sought, and received, Ms. Giuffre’s personal financial information. Specifically, she sought any payment information relating to the media. See Defendant’s First Set of Requests for Production at No. 30. Ms. Giuffre provided documents responsive to this request, which…
…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…
…idea. 19 Q. Did you meet her with the purpose 19 Q. Did you ever arrange payment for 20 of hiring her to work for Jeffrey or having 20 any of the employees at the home? 21 Jeffrey hire her? …
…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…
…all documents concerning any apartment or other dwelling occupied by Plaintiff from 1999 to the present, including but not limited to, all documents concerning the acquisition of, and payment for, such dwellings. This Request includes, but is not limited to…
…Ms. Giuffre objects to this information in that any payment information for the sexual trafficking she endured at the hands of Jeffrey Epstein and Ghislaine Maxwell is in the possession, custody and control of the Defendant and Jeffrey Epstein. 11…
…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…
…15 15. Defendant also demands items like personal financial documents from this non-party including payments she received from convicted sex offender Jeffrey Epstein and the men he “lent” this minor child out to from 1999 – 2002. See Exhibit 6…
…a sex slave;” (3) Request 18 “All documents concerning any monetary payments or other consideration received by Jane Doe #3 from any media outlet in exchange for her statements whether ‘on the record’ or ‘off the record’ regarding Epstein, Dershowitz…
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