…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTION AND IMPROPER CLAIM OF PRIVILEGE Plaintiff Virginia Giu…
…Avenue Denver, CO 80203 303.831.7364 TABLE OF CONTENTS INTRODUCTION ...................................…
…1332-9 Filed 01/08/24 Page 2 of 15 TABLE OF CONTENTS INTRODUCTION .......................................................................................................................... 1 I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG, RESULTING …
…21 Page 23 1 answer the question based on her Fifth l witness, and I will instruct the witness not to 2 Amendment privilege. 2 answer based on her Fifth Amendment privilege. 3 THE WITNESS: On the…
…AND HARASS THIS NON-PARTY........................................................18 IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20 V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO JANE DOE 43…
…AND HARASS THIS NON-PARTY........................................................18 IV. NON-PARTY MS. RANSOME SHOULD NOT BE FORCED TO INCUR THE BURDEN AND EXPENSE OF PRODUCING A PRIVILEGE LOG..............................20 V. NON-PARTY MS. RANSOME HAS PRODUCED DOCUMENTS RELEVANT TO JANE DOE 43…
… and August 1, 2016 Privilege Log. I declare under penalty of perjury that the foregoing is true and correct. /s/ Meredith Schultz______________ Meredith Schultz, Esq. Case 1:15-cv-07433-LAP Document 1332-4 Filed 01/08/24 Page…
…Electronic Message contains information from the Law Office of Martin G. Weinberg, P.C., and may be privileged. The information is intended for the use of the addressee only, If you are not the addressee, please note that any disclosure…
…D.C. 20005 Telephone: (202) 583-2500 Fax: (202) 583-0565 Mobile: (202) 595-4466 Web Site: www.gpoelaw.com This communication is intended solely for the use of the addressee. It may contain information that is privileged, confidential, exempt…
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…Filed 01/05/24 Page 4 of 40 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…Declaration, Mr. Cassell asserts that, because three of Epstein’s associates— —asserted their Fifth Amendment privilege against self-incrimination when questioned about me, it was reasonable for him to draw “adverse inference” to the effect that I “was, indeed, involved…
…question. I would instruct her not to 12 A. Maybe for a layover, but not that l 7.2 answer based on her Fifth Amendment privilege 13 specifically remember. 13 because the question assumes knowledge of 14 Q. Okay. Do…
…the 25 interrogatory limit set by Rule 33. Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…The transcript of that deposition is 418 pages long. Ms. Maxwell did not assert any privilege against self- incrimination and was questioned extensively about, among other things: her relationship with Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors…
…sexual partners . . . .”). Moreover, generally speaking, instructions from attorneys to their clients not to answer questions at a deposition should be “limited to [issues regarding] privilege.” Morales v. Zondo, Inc., 204 F.R.D. 50, 54 (S.D.N.Y. 2001)…
…15 MR. GUIRGUIS: I just 16 objected to that. You don't have 17 to answer. 18 MS. MENNINGER: Is there a 19 privilege you're asserting? 20 MR. GUIRGUIS: I'm not sure 21 what the relevance is, and…
…the 25 interrogatory limit set by Rule 33. Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…Filed 03/23/16 Page 4 of 45 Ms. Giuffre objects to Defendant’s First Set of Discovery Requests to the extent they seek information that is protected by any applicable privilege, including but not limited to, attorney client privilege…
…The transcript of that deposition is 418 pages long. Ms. Maxwell did not assert any privilege against self- incrimination and was questioned extensively about, among other things: her relationship with Jeffrey Epstein, her knowledge of “sexual trafficking,” sex with minors…
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