…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…
…Defendant refused to answer questions that go to heart of the type of questions this Court specifically ordered Defendant to answer: they could not be more on-point. None of Defendant’s arguments change the language of this Court’s…
…264-1). Yet, during her second deposition, Defendant again refused to answer numerous questions regarding sexual activity related to Jeffrey Epstein in contravention of this Court’s Order. Accordingly, the Court should direct her to fully answer the relevant questions…
…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…
…that substantial portions of her story are untrue; she has so far refused to say under oath what other lies printed by the press about her story are untrue, but has admitted that journalist Sharon Churcher “got it wrong.” For…
…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…
…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 substantial portions of her story are untrue; she has so far refused to say under oath what other lies printed by the press about her story are untrue, but has admitted that journalist Sharon Churcher “got it wrong.” For…
…21 14. Ms. Giuffre Has Not Refused To Produce Any Documents On The Grounds That They Are Available From Another Source ..............................22 15. Defendant’s Interrogatories Are Improper Under Local Rule 33.3.................22 16. …
…Releases ............................................. 8 E. Documents Concerning Plaintiff’s Claimed Prior Sexual Abuse Are Relevant and Discoverable............................................................................................................. 11 III. PLAINTIFF IMPROPERLY REFUSED INTERROGATORY RESPONSES…
…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…
…unavailing. First, Ms. Giuffre is entitled to question the Defendant on Defendant’s press agent who she refused to produce for a deposition, despite him being her agent and despite their sharing the same attorney, forcing Ms. Giuffre to litigate…
…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…
…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…
…1 suggests that the agreements are privileged, as plaintiff 2 argues. She has refused to identify when these individuals 3 began their representations, the nature of the representations. 4 THE COURT: There is a little confusion here, at least 5 …
…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…
…the people who would be in the best position to help me sort out what the names were [--] specifically Jeffrey Epstein, among others [--] have refused to cooperate and give me those names” (emphasis added). Ex. O at 36-37. 12…
…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…
…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…