gov.uscourts.nysd.447706.363.5.pdf PDF
…Check one: By handing it to a person identified to me as the Witness or by leaving it with the Witness who refused service. I attempted to serve the Witness on _______ occasions but have not been able to…
…Check one: By handing it to a person identified to me as the Witness or by leaving it with the Witness who refused service. I attempted to serve the Witness on _______ occasions but have not been able to…
…girl who looked well under 18 and recall asking her her age. I later leamed was a ballerina She refused to tell me or let me see her passport. 4. In addition to spending time with Jeffrey on his island…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…accepts the interview request by January 19. The attorney for her legal team confirmed to CNN that Buckingham Palace had refused to accept the letter to Prince Andrew and that it was returned to them. Buckingham Palace didn't respond…
…in this case, (b) the fact the information can be obtained from other sources, 1 Plaintiff flatly mis-represents to the Court that Ms. Maxwell “refused” to answer the questions posed to her, as the actual transcript amply demonstrates. Ms…
…Than Personal Service, and [DE 161] Declaration of Sigrid McCawley in Support of Plaintiff’s Motion for Leave to Serve Three Deposition Subpoenas By Means Other Than Personal Service.) Mr. Epstein refused to accept service, thereby forcing Ms. Giuffre to…
…of 40 within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the Defendant…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…She says she refused this > request.· Regarding further detail of the interview which I have reviewed I would like to add one further point to underscore the lack of probity in Ms Roberts claims At no point in Ms…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…The Hague, as Ms. Giuffre 4 Case 1:15-cv-07433-LAP Document 343 Filed 08/09/16 Page 5 of 8 is doing here. After counsel for Defendant refused to work with Ms. Giuffre to schedule Mr. Gow…
… Defendant Has Repeatedly Refused to Confer Regarding Their Document Collection Process After an unequivocal and flat refusal to discuss her ESI protocols (“ [w]e do not believe we have an obligation to describe for your [sic] our document search methods…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…of 40 within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the Defendant…
…this request are within the possession, custody and control of the defendant and Jeffrey Epstein with whom she claims a joint defense privilege and defendant has refused to produce responsive documents to Ms. Giuffre’s request seeking communications between the…
…do with,” “to have some connection or relation (to),” and “to have reference (to)”). Courts have condemned the use of “related to” as overbroad and have refused to compel a responding party to answer discovery requests using the term. See…