…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…for Adverse Inference Instruction); Docket Entry 338 (Supplement based in New Information). When Defendant refused to participate in electronic discovery, this Court ordered Defendant to collect and produce data based on mutually agreed upon search terms, (June 20, 2016 Order)…
…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…
…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…
…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…
…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…
…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…
…s counsel, Philip Barden, is also counsel for Mr. Gow. Mr. Barden refused to accept service of process of Ms. Giuffre’s Rule 45 subpoena on Mr. Gow’s behalf, despite extensive correspondence with Ms. Giuffre’s counsel, and her…
…used during the relevant period were excluded from this “search.” Moreover, Defendant has inappropriately refused to disclose what email accounts she has used during the relevant period for which this Court ordered her to produce documents. In the briefing, Ms…