…claims to have been abused and one month prior to the purported defamation. Plaintiff has offered no plausible explanation for her expansive time frame as discussed below. The gist of Plaintiff’s temporal relevance argument is that, according to Plaintiff…
…Therefore, both of these documents are highly relevant. Whatever Defendant argues about her prior deposition, she cannot claim that she was questioned about these two emails. Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery…
…very next page, when discussing the information gleaned from those police reports that Mr. Pagliuca had prior to the conferral call, Defendant claims the information from the police reports is “irrelevant,” stating: “The records requested are irrelevant. Plaintiff has asserted…
…prior to and subsequent to Defendant’s January 3, 2015 defamation of Ms. Giuffre are listed in the supplemental responses for both Interrogatories 12 and 13. There may be additional crossover of providers that have treated Ms. Giuffre subsequent to…
…N.Y. Jan. 7, 2008) (defense entitled to discovery of prior sexual history and treatment for bulimia and depressions which might show that emotional distress caused at least in whole or part by other events); Rhodes v. Motion Indus., Inc…
…our society. THE OVERBROAD SEALING ORDER AND PRIOR ATTEMPTS TO UNSEAL During litigation of the defamation claim, the Court, upon Defendant's motion, entered an overly broad Protective Order stating, inter alia: This Protective Order shall apply to all documents…
…practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b)…
…6 seeks documents relating to Maxwell’s communications with Sarah Kellen. At a prior deposition, Sarah Kellen invoked her Fifth Amendment privilege when asked: Q. Would you agree with me that Ghislaine Maxwell provides underage girls to Mr. Epstein for…
…practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b)…
…requested information relating to how Defendant 7 Case 1:15-cv-07433-LAP Document 1199-1 Filed 01/27/21 Page 8 of 13 obtained these reports (and/or the identifying information concerning the victim) prior to the March…
…instruction not to answer was given. These questions had been asked in the first deposition, could have been asked in greater detail in the first deposition, and were answered in both depositions prior to the instruction not to answer being…
…ROUGH***Deposition of Tony Figueroa*** ROUGH*** 161 1 lead to where is she, so... 2 Q How did Jeffrey Epstein have you telephone 3 number? 4 A I would imagine from Virginia. 5 Q Okay. What prior to her going…
…instruction not to answer was given. These questions had been asked in the first deposition, could have been asked in greater detail in the first deposition, and were answered in both depositions prior to the instruction not to answer being…
…53 of of 43 41 Table of Contents I . Prior Proceedings . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 II.The Motion to Intervene is Grante…
…prior to the Defendant’s defamation. Defendant does not include Ms. Giuffre’s hard-won and fulsome answer, which includes a bevy of providers going back many years. The reason for Defendant’s Rule violation with regard to this 10…
…whom You received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or illegal drugs, that You suffered from prior to the Alleged Defamation by Ghislaine Maxwell, including: a. the Health Care Provider’s name…
…Letter Brief to Judge Sweet Regarding Defendant’s Refusal to Sit for a Deposition. Defendant’s tactic of stonewalling and delay is the underlying problem, and requiring a meet and confer prior to the Court addressing this conduct would reward…
…Heaney, Donna Oliver P.A., and Dr. Streeter. Defendant did not learn of these providers 10 days prior to the close of discovery, but much earlier, as the previous page of Defendant’s brief recounts. 8 (1) Dr. Steven Olson…
…emphasis supplied). This “reasoning” is fundamentally flawed. Ms. Maxwell stated in her responses to the RFPs that “prior to this litigation [she] has long had a practice of deleting emails after they have been read.” Menninger Decl., Ex.B ¶ 16…
…practical method of obtaining the information sought than a request for production or a deposition,” and because they were served in advance of the period “30 days prior to the discovery cut-off date.” Local Civil Rule 33.3(b)…
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