…Account Ms. Giuffre has knowledge of the account because it was listed as part of Defendant’s contact information (including phone number) on documents gathered by the police from Epstein’s home, and turned over to the Palm Beach County…
…MORGAN AND FOREMAN, P.C. 111 150 East 10 Avenue Denver, CO 80203 Phone: 303.831.7364 Fax: 303…
…other personal identifying information (addresses, dates of birth, phone numbers) of the same. ARGUMENT The Governing Law Establishes a Substantial Presumption of Access to All of the Documents at Issue Both Ms. Maxwell and J. Doe selectively…
…Defendant then argues that Ms. Ransome should therefore be punished by having to make burdensome and invasive disclosures of such things as her boyfriend’s cell phone number and information from her current bank account. Unwilling to confine her attacks…
…Defendant then argues that Ms. Ransome should therefore be punished by having to make burdensome and invasive disclosures of such things as her boyfriend’s cell phone number and information from her current bank account. Unwilling to confine her attacks…
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a master of list of underage minor females names and phone numbers so they could be called for the purpose of coming to Jeffrey Epstein’s house to be sexually molested…
…journals, calendars, blog posts (whether published or not), notes (handwritten or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name. RESPONSE: Ms. Maxwell…
…App. Div. 2016). 13. All phone records for any cellphone owned, used or possessed by You during the years 2006- 2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is…
…relevance argument asserted by the Motion, this issue should be deemed admitted. Compare Motion at 10-11; Opp’n at 19. Category 2 - the cell phone number of her partner. In opposition, Ms. Ransome asserts, without factual or legal support…
…App. Div. 2016). 13. All phone records for any cellphone owned, used or possessed by You during the years 2006- 2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is…
…relevance argument asserted by the Motion, this issue should be deemed admitted. Compare Motion at 10-11; Opp’n at 19. Category 2 - the cell phone number of her partner. In opposition, Ms. Ransome asserts, without factual or legal support…
…App. Div. 2016). 13. All phone records for any cellphone owned, used or possessed by You during the years 2006- 2007. RESPONSE: In addition to the Preliminary Statement and General Objections, Ransome objects to this request in that she is…
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a master of list of underage minor females names and phone numbers so they could be called for the purpose of coming to Jeffrey Epstein’s house to be sexually molested…
…journals, calendars, blog posts (whether published or not), notes (handwritten or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name. RESPONSE: Ms. Maxwell…
…CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell …
…yourself, Ghislaine Maxwell and Sarah Kellen had access to a master of list of underage minor females names and phone numbers so they could be called for the purpose of coming to Jeffrey Epstein’s house to be sexually molested…
…CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell 14 Case 1:15-cv-07433-LA…
…they reference her by name.” A search of the attorneys’ files for all documents that “concern” Plaintiff is the search to which the defense has objected (repeatedly, in writing and on the phone) and about which counsel has stated, correctly…
…assume that we withdraw that lawsuit tomorrow, which 13 we won't, he would still have criminal exposure -- 14 THE COURT: Hold the phone just a second. You just 15 said Epstein has criminal issues -- 16 MR. CASSELL: Exposure. 17 …
…CO 80203 Phone: 303.831.7364 Fax: 303.832.2628 [email protected] Attorneys for Ghislaine Maxwell 14 Case 1:15-cv-07433-LAP Docum…