…696, 716 (1983) (Brennan, J. concurring). It thus “protects two different interests of the citizen—the interest in retaining possession of property and the interest in maintaining personal privacy.” Id. (cleaned up). “A seizure threatens the former, a search the…
…2016). Thus, Ms. Maxwell’s decision to sell the property, made long before this litigation, by definition could not have been informed by this litigation or demonstrate “consciousness” of guilt or civil liability. Second, Plaintiff’s claim that information regarding…
…says he didn't turn this over before, because in the first 22 bracketed paragraph 1 at the end of paragraph 9, it was his 23 property and he should be compensated for it. So Rodriguez, to 24 the FBI…
…complaints. Plaintiff fails to cite to a single instruction not to answer that 1) falls within the scope to the Court’s Order and 2) that was not answered when properly rephrased to fall within the scope of the Order…
… I don't believe clothing was seized. 3 Q. To your knowledge, did you seize any 4 property belonging to Ghislaine Maxwell from the 5 home? 6 MS. SCHULTZ: Object to form and 7 foundation. 8 THE WITNESS: I'm…
…23 Confidential Page 89 1 G. Maxwell - Confidential 2 were sex toys or devices used in sexual 3 activities in Mr . Epstein ' s property in the 4 Vi rgin Islands? 5 MR. PAGLIUCA : Obj ection to form 6 and foundation…
… I don't believe clothing was seized. 3 Q. To your knowledge, did you seize any 4 property belonging to Ghislaine Maxwell from the 5 home? 6 MS. SCHULTZ: Object to form and 7 foundation. 8 THE WITNESS: I'm…
…Natalya Malyshov, Sarah Kellen, and Nadia Marcincova. 4. All Communications You have had in whatever form with any other female who you ever witnessed at or in a property, home, business, plane or automobile other vehicle owned or controlled by…
…you look for all photographs A. Yes. taken by you or containing any image of you at or near any home, business, private vehicle or any other property owned or controlled by Jeffrey Epstein, as indicated in paragraph 7? Q…
…and she never engaged in any sexual activity, nor was it ever requested; and 3) all interactions she had at Mr. Epstein’s property of a sexual nature were consensual activities while she was an adult. Pagliuca Decl., Ex. E…
…Philip Barden, “to waive service of process.” Indeed, “[o]nce documents have been properly transmitted to a Hague Convention Central Authority, the period for completion of service of process may be extended, as ‘the timing of service is out of…
…But, if Plaintiff insists that Ms. Ransome should testify at trial, she must comply with properly served and propounded subpoena for testimony and records. 1 To avoid excessive and duplicative briefing on overlapping issues, Ms. Maxwell is submitting her Response…
…sensitive subjects without it being disclosed to the public, absent an additional order of this Court. The Protective Order served "to protect the discovery and dissemination of confidential information or information which will properly annoy, embarrass, or oppress any party…
…162 (2d Cir. 2012). “Spoliation is ‘the destruction of evidence, or the failure to preserve property for another's use as evidence in pending or reasonably foreseeable litigation.’” MASTR Adjustable Rate Mortgages Trust, 295 F.R.D. at 82 (quoting…
…the Court allow a person to intervene in a case if that person “claims an interest relating to the property or transaction that is the subject of that action and is so situated that disposing of the action may as…
…you look for all photographs A. Yes. taken by you or containing any image of you at or near any home, business, private vehicle or any other property owned or controlled by Jeffrey Epstein, as indicated in paragraph 7? Q…
…23 Confidential Page 89 1 G. Maxwell - Confidential 2 were sex toys or devices used in sexual 3 activities in Mr . Epstein ' s property in the 4 Vi rgin Islands? 5 MR. PAGLIUCA : Obj ection to form 6 and foundation…
…however, we here clarify that (1) the judicial nature of a document is properly determined at the time it is filed such that a motion that is a judicial document when filed does not cease to be so because, before…
…because no such duty existed. “Spoliation is the destruction or significant alteration of evidence, or the failure to preserve property for another's use as evidence in pending or reasonably foreseeable litigation.” Kraus v. General Motors Corp., 2007 WL 3146911…
…Virgin Islands. These requests seek information about Defendant’s sexually trafficking of minors, including documents relating to her flying girls to be with Epstein.27 Related to the trafficking, Epstein’s Caribbean property is only reachable via helicopter or boat…
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