…INTRODUCTION .......................................................................................................................... 1 I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG, RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1 II. MS. RANSOME REFU…
…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…
…INTRODUCTION .......................................................................................................................... 1 I. MS. RANSOME UNJUSTIFIABLY FAILED TO PRODUCE A PRIVILEGE LOG, RESULTING IN A WAIVER OF HER PRIVILEGE ............................................................ 1 II. MS. RANSOME REFU…
…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…
…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…
…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. …
…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…
…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…
…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…
…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…
…that she may invoke her Fifth Amendment rights. Instead, during her recent deposition, Defendant simply failed to recall many of the most significant events in this case or refused to respond directly to many important questions. As a result, Ms…
…citing her three passports and claimed she is worth more than $10M They said Maxwell refused to open the front door to the FBI and tried to flee to another room when they raided her $1 million home on…
…that she may invoke her Fifth Amendment rights. Instead, during her recent deposition, Defendant simply failed to recall many of the most significant events in this case or refused to respond directly to many important questions. As a result, Ms…
…NOT HAVE DOCUMENTS FOR A NUMBER OF REQUESTS. Defendant’s Motion to Compel3 is misleading because it suggests that non-party Ms. Ransome refused to produce documents in response to all thirty categories in the subpoena. That is 2 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…
…unequivocally that they sat down and made this all up, tragically it will hurt all rape victims. . . The lawyers are lying through their teeth when they say I've refused to be deposed. . . . We [Epstein and Dershowitz] had an academic…
…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…
…a 6 massage mention that they expected something sexual? 7 A. No. 8 Q. Did they ask you to engage in sexual 9 contact and you refused? 10 MS. McCAWLEY: Objection. 11 THE WITNESS: No. 12 BY MS. MENNINGER: 13 …
…that she may invoke her Fifth Amendment rights. Instead, during her recent deposition, Defendant simply failed to recall many of the most significant events in this case or refused to respond directly to many important questions. As a result, Ms…
…that statement and decided to approach 23 the reporter to try to sell her story. She did that just a 24 couple weeks before she called plaintiff's counsel. That 25 New York Post reporter refused, apparently, to publish her …