…20 12. Victims Refuse Silence is a sham not-for-profit established to create a claim for defamation per se (Motion in Limine 12)...................................................................... 20 i Case 1:15-cv-07433-LAP Do…
…and Defendant has provided no evidence other than the fact of his representation of Plaintiff ' s non - profit to doubt that the communications logged are privi l eged. Having provided no grounds to doubt the sworn representations of Plaintiff ' s…
…Plaintiff’s proposal included astoundingly broad terms, to wit: x “Terramar” -- both the name of Ms. Maxwell’s non-profit and x x x “max*” – part of Ms. Maxwell’s last name, as well as all of her paternal relatives…
…injuries. In contrast, Taylor does not offer opinions that fall within the competence of an accountant, such as financial reports and loss/profit ledgers. Instead, he ventures far afield . Such is the stuff of an attorney’s closing argument, not…
…been produced. Plaintiff also produced an email to but not any response to that email. The iCloud account also discloses a previously undisclosed potential witness, , a person working at a not-for-profit relating to sexual trafficking victims. Apparently, in…
…at 86, since it is difficult to prove what is contained in documents that have been destroyed. To require a detailed showing in such circumstances poses the danger that “the spoliator [may] profit from its” own misconduct. Id. (quoting Orbit…
…wit: Plaintiff’s originally proposed search terms would literally hit on every single email from either Ms. Maxwell’s personal or her business email addresses, as well as every document related to the non-profit, The Terramar Project, that Ms…
…at 86, since it is difficult to prove what is contained in I documents that have been destroyed . To require a detailed showing in such circumstances poses the danger that "the spoliator [may] profit from its" own misconduct. Id. (quoting…
…The time to negotiate search terms has long passed; this Court should not countenance Defendant profiting from her refusal to comply with her discovery obligations and from her refusal to obey this Court’s Order. Dated: August 1, 2016 Respectfully…
…this woman, Virginia Roberts. CNN is naming her because she has gone public with her name. So is that the best way for celebrities and high-profile people to handle allegations like this? PAUL CALLAN, CNN LEGAL ANALYST: Well, Alan…
…evidentiary, as to the facts alleged in the pleading.” 2 In actuality, it appears that the very purpose of Plaintiff’s inclusion in the CVRA action of explicitly detailed allegations of sexual interaction with high profile individuals including Ms. Maxwell…
…www.nydailynews.com/new-york/ny-jeffrey-epstein-ghislaine-maxwell-deposition-20201022-wtdmj6xdejcvzeyydttim6oxuq-story.html 243 https://lawandcrime.com/high-profile/ghislaine-maxwells-massive-2016-deposition-finally-released-read-it-all-here/ 244 https://www.bpr.org/post/jeffrey-epstein…