…Creations Article “Prince Andrew’s Friend, Ghislaine Maxwell, Some Underage Girls, and A Very Disturbing Story,” attached hereto as Exhibit 26. 27. Photographs, attached hereto as Exhibit 27. 28. April 13, 2010 Deposition Transcript of Nadia Marcinkova, attached hereto as …
…there.” Cassell Decl., ¶ 21(k). He then asserts that “Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as Dershowitz.” Id. Mr. Cassell’s characterization of the…
…Despite these obstacles, non-party Ransome complied by producing over 235 pages of highly relevant documents which include photographic evidence and e-mail communications during the mid-2000s that directly contradict Defendant’s deposition testimony. For example, Defendant swore under…
…they went out and badgered the victims, they went through all social media, found photographs of these victims either holding an alcoholic beverage and calling them -- you see they're not saints. You know, they're consuming alcohol under the…
…is pretty spiritual so he said the best thing to do would be burn them. Q. Is there anything you decided to keep and not burn? A. Just the photographs. Q. Anything else that you can think of? A. Photographs…
…to accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the years that she swore under oath that she was hardly around. Ms…
…16 When you went into the bedroom of Jeffrey 17 Epstein, everything was removed from the -- the 18 shelves, from the armoire. 19 Q. Did you find nude photographs of girls? 20 A. Yes. 21 Q. All right. 22 And…
…and cannot be considered here.’” (citing Fonte v. Bd. of Managers of Cont'l Towers Condo., 848 F.2d 24, 25 (2d Cir. 1988))); Bill Diodato Photography LLC v. Avon Prod., Inc., No. 12 CIV. 847 RWS, 2012 WL 3240428…
…to accomplish that purpose. Ms. Ransome also produced numerous photographs of her travels to Epstein’s Little Saint James Island, which unequivocally establish Defendant’s presence during the years that she swore under oath that she was hardly around. Ms…
…and description that is or has been in Your possession, custody or control, or of which You have knowledge, including but not limited to, emails, text messages, instant messages, videotapes, photographs, notes, letters, memoranda, forms, books, magazines, resumes, notebooks, ledgers…
…witness Ms. Ransome has provided more significant evidence, including photographic evidence and electronic communications, than Defendant has produced in the two years she has been litigating this matter. Defendant has not produced a single document prior to 2009 and not…
…in March 2011, when she wrote a series of articles published in The Mail on Sunday and affiliated newspapers containing extensive interviews with and photographs of Giuffre, in which she "agreed to waive her anonymity a nd tell for the…
…there.” Cassell Decl., ¶ 21(k). He then asserts that “Alessi was able to identify a photograph of Ms. Giuffre as someone who was at the mansion as [sic] the same time as Dershowitz.” Id. Mr. Cassell’s characterization of the…
…Epstein. 5. All Communications You have had with , Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, . 6. Any photographs containing any image of Virginia Roberts, Ghislaine Maxwell, Jeffrey Epstein, . 7. …
…only after Ms. Maxwell uncovered their existence. Similarly, Plaintiff was specifically asked for photographs of Plaintiff with certain individuals (including Prince Andrew), and production of those photographs in native format. Plaintiff claimed she produced documents she had, but did not…
…non-compliant since the outset of discovery.” (Mtn. at 11). This statement is completely inaccurate. Defendant makes a number of unsubstantiated claims regarding law enforcement materials, photographs, and email accounts. Most of these issues have been resolved pursuant to this…
…only after Ms. Maxwell uncovered their existence. Similarly, Plaintiff was specifically asked for photographs of Plaintiff with certain individuals (including Prince Andrew), and production of those photographs in native format. Plaintiff claimed she produced documents she had, but did not…
…give her address, much less any initial 20 disclosures under Rule 26 of corroborating evidence, like her 21 own travel records, or her own photographs, or anything else 22 that they would use to support this claim. So waiting, your …
…witness Ms. Ransome has provided more significant evidence, including photographic evidence and electronic communications, than Defendant has produced in the two years she has been litigating this matter. Defendant has not produced a single document prior to 2009 and not…
…non-compliant since the outset of discovery.” (Mtn. at 11). This statement is completely inaccurate. Defendant makes a number of unsubstantiated claims regarding law enforcement materials, photographs, and email accounts. Most of these issues have been resolved pursuant to this…
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