…Evidence ........................................................................................................... 2 C. Ms. Maxwell Already Has Fully Responded to All Discovery Requests Relating to Payments Made to Her By Epstein ...................................................................................... 5 …
…cv-07433-LAP Document 1202-1 Filed 01/27/21 Page 3 of 11 documents relating otherwise to Plaintiff including her hospital records (RFP 25), passport (RFP 26), monetary payments made to her (RFP 27), her employment (RFP 28)…
…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 …
…6. Attached hereto as Exhibit 4, is a true and correct copy of the 2009 Notice of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. 7. Attached hereto as Exhibit 5, is…
…Letter. 10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail Article. 11. Attached hereto as Exhibit 9…
…Statement. 10. Attached hereto as Composite Exhibit 8, is a true and correct copy of the Notice of Deposition of Ghislaine Maxwell, Subpoena and Cancellation Payment Notice, and January 13, 2015 Daily Mail, “Bill Clinton pictured with Jeffrey Epstein’s…
…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…
…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…
…cv-07433-LAP Document 1327-12 Filed 01/05/24 Page 3 of 11 x documents relating otherwise to Plaintiff including her hospital records (RFP 25), passport (RFP 26), monetary payments made to her (RFP 27), her employment (RFP 28)…
…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 …
…cv-07433-LAP Document 1202-1 Filed 01/27/21 Page 3 of 11 documents relating otherwise to Plaintiff including her hospital records (RFP 25), passport (RFP 26), monetary payments made to her (RFP 27), her employment (RFP 28)…
…05/24 Page 9 of 22 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…
…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…
…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…
…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…
…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…
… 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…
…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…
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