…the Southern District of Florida (the “Office”), the Office was recused by the Department of Justice from prospective responsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein’s alleged sexual activities with minor females. As a result…
…in which she works – the U.S. Attorney’s Office for the Southern District of Florida – has been recused by the Justice Department “from prospective responsibility for any criminal investigation or potential prosecution relating to Jeffrey Epstein’s alleged sexual…
…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…
…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…
…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…
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY IN THIS ACTION ................................................................................................................... 5 III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10 IV. MS. RA…
…Releases ............................................. 8 E. Documents Concerning Plaintiff’s Claimed Prior Sexual Abuse Are Relevant and Discoverable............................................................................................................. 11 III. PLAINTIFF IMPROPERLY REFUSED INTERROGATORY RESPONSES…
…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…
…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…
…2 B. As a Retained Expert, Phillip Esplin Cannot Be Deemed Unavailable ............................... 3 II. TESTIMONY IN WHICH WITNESS REFUSED TO RESPOND TO QUESTIONS POSED IS IRRELEVANT, MORE PREJUDICIAL THAN PROBITIVE, AND MUST BE EXCLUDED FROM TRIAL ...................................................................…
…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…
…ARE HIGHLY RELEVANT TO MS. RANSOME’S TESTIMONY IN THIS ACTION ................................................................................................................... 5 III. MS. RANSOME UNJUSTIFIABLY REFUSED TO ANSWER RELEVANT DEPOSTION QUESTIONS, AND SHE MUST BE COMPELLED TO RE-APPEAR AND RESPOND . 10 IV. MS. RA…
…Civ. P. 26(f)(3)(C). Defendant having admitted to deletion practices that indicate relevant documents and also refused to detail document search methods, good cause exists to warrant court supervised examination of her electronic devices. Accordingly, Plaintiff’s motion…
…Against this backdrop of broad discovery rights, Maxwell has refused to produce responsive documents. B. Maxwell’s General Objections Fail The centerpiece of Maxwell’s general objections is her disingenuous limitation of her discovery responses to a short window of…
…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…
…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…
…168, 222 (S.D.N.Y. 2013) (granting an adverse inference when defendants refused to produce documents pursuant to the District Court’s order). Where “an adverse inference ... is sought on the basis that the evidence was not produced in…
…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…
…she said she cannot remember where the photograph is, where the contract is, what she told Churcher, and she refused upon advice of counsel, to state what stories Churcher “got wrong.” See Motion to Re-Open Deposition of Plaintiff. Second…
…Giuffre either return or destroy all confidential information, including her deposition transcripts. Boies Schiller refused. . The Government’s False Statements To Only in August 2020, after she was indicted in this case, did Maxwell finally …