…late production of important emails. These two issues developed as follows. Defendant’s Failure to Answer Certain Questions During her first deposition, Defendant improperly refused to answer certain questions. Accordingly, the Court ordered a second deposition, directing the Defendant to…
…Despite our requests, Ms. Giuffre’s lawyers have refused to return or destroy the Confidential Materials. Instead, they have indicated they wish to use the Confidential Materials in another case they are pursuing. The Protective Order on which all the…
…directed Maxwell to sit for her deposition on April 22, 2016. During her deposition Defendant refused to answer the majority of the questions asked or stated that she had no memory of any of the events. As a result, Ms…
…Despite our requests, Ms. Giuffre’s lawyers have refused to return or destroy the Confidential Materials. Instead, they have indicated they wish to use the Confidential Materials in another case they are pursuing. The Protective Order on which all the…
…that the collision had been caused or contributed to by the deceased's own negligence, refused to disclose the report on the ground, as stated in an affidavit sworn on their behalf, ^ that one of the principal purposes of…
…the Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition concerning highly relevant, non-privileged information.3 Alternatively, if the…
…confidential information at the conclusion of the case, including Maxwell’s deposition transcripts. refused to do so although ordered to do so by Judge Sweet.3 In its application to , the government . Not only did the government misunderstand how the…
…deposition, but as is her wont, inaccurately summarizes the deposition and falsely claims that Ms. Maxwell refused or failed to answer a number of questions concerning events purportedly occurring 15 years prior. See DE 172 at 5-8. Ms. Maxwell…
…the foregoing, Ms. Maxwell responds as follows: Plaintiff was advised by her own physician in Australia to engage in psychotherapy but has refused to do so. Plaintiff was advised to cease taking valium but has refused to do so. Plaintiff…
…2019). 3 Doe 171 has to date refused to provide Plaintiff with all ex parte submissions or briefs she provided to the Court. 2 Case 1:15-cv-07433-LAP Document 1289 Filed 12/07/22 Page 3 of…
…annoyance or embarrassment if unsealed” because, inter alia, she “refused to testify as to any consensual adult activity behavior and generally disclaimed any knowledge of underage activity.” TR 7/23/2020, p 4. This Court declined to keep sealed this…
…the Daily Mail, who filed a Motion to Quash her subpoena on the day before her scheduled deposition,2 and (2) Plaintiff, who refused to answer questions at her deposition concerning highly relevant, non-privileged information.3 Alternatively, if the…
…2021 Page 3 be a renewed attempt to re-serve the Non-Parties with no return address, but Maxwell refused because her objection would remain even for a Non-Party that was actually served but did not object. In short…
…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…
…Mr. Rizzo’s testimony about how Defendant took the passport of a 15-year-old Swedish girl and threatened her when she refused to have sex with Epstein cannot be given to the media.6 Likewise Mr. Alessi’s testimony…
…Co., 594 F.2d 291, 296–97 (2d Cir. 1979) (“In the present case the deponents testified in reliance upon the Rule 26(c) protective order, absent which they may have refused to testify. . . . [T]he witnesses were entitled to…
…cost. II. AN ADVERSE INFRERENCE INSTRUCTION IS WARRANTED In this litigation as the Court will recall, Defendant first refused to produce any documents at all - Ms. Giuffre had to litigate for Defendant to commence discovery (DE 28). Defendant then refused…
…Ms. Giuffre has made this collection in compliance with a standard ESI Protocol that was provided to Defendant, but that Defendant has refused to comply with. Courts have found this to be the best practice to ensure compliance with Fed…
… 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…
…65th St. for $15 million.” See http://nypost.com/2016/04/28/alleged-epstein- madam-sells-16m-manhattan-townhouse/. When questioned about the sale, Defendant’s representative refused to comment. See id. (broker Shari Scharfer Rollins, of Douglas Elliman, did…