Found 19 results for “record” in 460ms

gov.uscourts.nysd.447706.895.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.895.0 3 pg

…Morgan & Foreman, P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Ms. Maxwell’s Response In Opposition to Plaintiff’s Notice Pursuant to Rule 415 of Similar Acts…

gov.uscourts.nysd.447706.1111.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1111.0 69 pg

…Defendant. / THE GOVERNMENT OF THE UNITED STATES VIRGIN ISLANDS’ MEMORANDUM OF LAW IN SUPPORT OF EX PARTE MOTION TO INTERVENE AND FOR CONFIDENTIAL ACCESS TO JUDICIAL RECORDS AND DISCOVERY DOCUMENTS The Government of the United States Virgin Islands (the “USVI…

gov.uscourts.nysd.447706.1320.34.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.34 4 pg

…P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and Failure to…

1320-34.pdf PDF

giuffre-maxwell 1320-34 4 pg

…P.C., counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action. I respectfully submit this declaration in support of Defendant’s Motion for Rule 37(b) &(c) Sanctions for Failure to Comply with Court Order and Failure to…

gov.uscourts.nysd.447706.1256.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.17 4 pg

…the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger…

gov.uscourts.nysd.447706.1068.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1068.0 31 pg

…Abuse” Does Not Warrant Continued Sealing. ................. 9 C. The Protective Order Does Not Warrant Continued Sealing. ................................... 10 D. The “Abuse of Court Records and Files” Does Not Warrant Continued Sealing. ... 12 E. “Annoyance, Embarrassment, Oppression, a…

gov.uscourts.nysd.447706.308.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.308.0 7 pg

…1, Affidavits of Service of Process related to Kellen; and Exhibit 2, July 21, 2016, Deposition Record Transcript. The subpoena directed that Ms. Kellen appear at the offices of Boies, Schiller, and Flexner in New York on July 21, 2016…

gov.uscourts.nysd.447706.1320.33.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.33 24 pg

…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…

gov.uscourts.nysd.447706.1198.1_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1198.1_2 24 pg

…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…

1320-33.pdf PDF

giuffre-maxwell 1320-33 24 pg

…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…

gov.uscourts.nysd.447706.712.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.712.0 11 pg

…the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger…

gov.uscourts.nysd.447706.231.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.231.0 23 pg

…Comply with Rule 26(a), stating as follows: CERTIFICATE OF CONFERRAL The undersigned has conferred with Plaintiff’s counsel on multiple occasions in an attempt to obtain records and interrogatory responses Ordered by the Court, including by letter dated April…

gov.uscourts.nysd.447706.375.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.375.0 4 pg

…the Clerk of Court by using the CM/ECF system. I also certify that the foregoing document is being served to all parties of record via transmission of the Electronic Court Filing System generated by CM/ECF. Laura A. Menninger…

gov.uscourts.nysd.447706.1330.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1330.11 12 pg

…Palm Beach County State Attorney as part of - the investigation and prosecution of Epstein. M Ghislaine Maxwell See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16- 268, Disc 7 at p. 2305 (GIUFFRE007843)…

gov.uscourts.nysd.447706.1219.22.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.22 22 pg

…Moreover, as noted above, the record is replete with multiple examples of Defendant failing to recall obvious and highly incriminating facts. Given Defendant’s amnesia about important events, it seems obvious that she may similarly be 17 Case 1:15…

gov.uscourts.nysd.447706.561.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.561.0 22 pg

…only knew that the statements were false but indeed actively participated in fabricating false statements. The record is completely devoid of evidence to support the existence of any such basis. McCawley Dec., Exhibit 2 (Summary Judgment Motion) at 12. Ultimately…

gov.uscourts.nysd.447706.1200.11_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1200.11_1 21 pg

…over to the Palm Beach County State Attorney as part of the investigation and prosecution of Epstein: See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16- 268, Disc 7 at p. 2305 (GIUFFRE007843). …

gov.uscourts.nysd.447706.1257.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1257.2 21 pg

…over to the Palm Beach County State Attorney as part of the investigation and prosecution of Epstein: See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16- 268, Disc 7 at p. 2305 (GIUFFRE007843). …

gov.uscourts.nysd.447706.1327.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.19 21 pg

…over to the Palm Beach County State Attorney as part of the investigation and prosecution of Epstein: See (DE 280-2), Palm Beach County State Attorney’s Office, Public Records Request No.: 16- 268, Disc 7 at p. 2305 (GIUFFRE007843). …

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