giuffre-maxwell
gov.uscourts.nysd.447706.1296.2
17 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.1_1
17 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.17
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.5
17 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.1_1_1_1
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly ·'adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.6
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.10_2
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
gov.uscourts.nysd.447706.143.0
10 pg
…counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly “adult” sexual activity related
to Jeffrey Epstein. Because this activity is highly relevant to this case…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.1
17 pg
…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…
giuffre-maxwell
1320-6
10 pg
…Instead
of allowing Ms. Giuffre to take a full and complete deposition, Defendant flatly refused to
-
answer questions critical to the key issues in this case. Contrary to Defendant’s assertions, Ms.
Giuffre is not engaged in a “fishing expedition…
giuffre-maxwell
1320-2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.2
10 pg
…and through her undersigned counsel, hereby files this
Motion to Compel Defendant to Answer Deposition Questions. During her recent deposition,
Defendant refused to answer numerous questions about allegedly .. adult'' sexual activity related
to Jeffrey Epstein. Because this activity is highly…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.7
12 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…...........................................................8
E. Plaintiff Has Not Refused To Provide Addresses And Telephone Numbers ..............10
F. Defendant Is Not Prejudiced And She Has Not Made A Showing of Prejudice.........11
CONCLUSION ..............................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.78.0
30 pg
…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. …
giuffre-maxwell
gov.uscourts.nysd.447706.99.0
22 pg
…Releases ............................................. 8
E. Documents Concerning Plaintiff’s Claimed Prior Sexual Abuse Are Relevant and
Discoverable............................................................................................................. 11
III. PLAINTIFF IMPROPERLY REFUSED INTERROGATORY RESPONSES…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…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 ...................................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.57.1
26 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…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 …
giuffre-maxwell
gov.uscourts.nysd.447706.1206.13
22 pg
…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…