…so that solicitors could provide legal advice in connection with expected proceedings – Implied statutory duty to investigate but no duty to report – Affidavits did not enable court to conclude that claim for privilege established – Maker of affidavits required to swear…
…particularly in light of Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a…
…particularly in light of Ms. Giuffre’s punitive damages claim as well as press reports suggesting that the Defendant may be selling her assets in New York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a…
…22 Page 3 of 30 TABLE OF AUTHORITIES Page Cases Candelaria v. Erickson, 2006 WL 1636817 (S.D.N.Y. 2006) ................................................................…
…21 Page 3 of 30 TABLE OF AUTHORITIES Page Cases Candelaria v. Erickson, 2006 WL 1636817 (S.D.N.Y. 2006) ................................................................…
…Court suspending the First Amendment right of access). Mr. Cernovich’s journalistic focus is on Maxwell and in reporting on Jeffrey Epstein’s accusations.2 In fact, in the 2016 presidential election, Epstein’s activities were the focus of political…
…CONCLUSION ............................................................................................................................. 23 i TABLE OF AUTHORITIES …
…F.S. t2 I n I \ A gnature Date ' …
…21 Page 3 of 30 TABLE OF AUTHORITIES Page Cases Candelaria v. Erickson, 2006 WL 1636817 (S.D.N.Y. 2006) ................................................................…
…Second set of Requests for Production on April 14. Those Requests primarily concerned police reports about Plaintiff’s various contacts with law enforcement and how the defense was able to obtain those publicly-available documents (RFP’s 1-5, 19)…
…For reasons that are not clear, the press seemed to be uninterested. As the Epstein story has now been reported by major every network and publication in the world, Mr. Cernovich's work as a reporter has had the desired…
…turning on whether Defendant defamed Ms. Giuffre by calling her a liar when Ms. Giuffre reported the sexual abuse she suffered as a minor child. Ms. Giuffre has sought to move the case along towards the projected trial date in…
…Entry 152 summarizes publicly available statements. Page 6 summarizes (1) Doe 1’s statements to law enforcement in a report that is already entirely public and (2) the entirely publicly available deposition testimony of a deceased Non-Party. That page…
…Communications, LLC, d/b/a The Gateway Pundit wishes to report on the Epstein Client List. Although this Court has been engaged in a process to unseal records that never should have been denied public access in the first place…
…For another example, Defendant represented to the Court that Ms. Giuffre’s rape (where the presence of blood and semen was noted by the police report) was a “simulated sex act” (DE 335). For another example, Defendant put forth to…
…24 . Yet, Plaintiff did not report this treatment or identify these health care providers in her Initial Disclosures or Interrogatory Reponses. She also purposefully left this information out of her testimony relating to doctors she has seen after January 2…
…24 . Yet, Plaintiff did not report this treatment or identify these health care providers in her Initial Disclosures or Interrogatory Reponses. She also purposefully left this information out of her testimony relating to doctors she has seen after January 2…
…prove 4 See Declaration of Sigrid McCawley (“McCawley Decl.”) at Exhibit 1, Palm Beach Police Report. 5 Defendant disregarded Ms. Giuffre’s requested date range of 1999 to the present and unilaterally limited her production to the years 1999 – 2002…
…the Virgin Islands and then helicoptered to Little St. James. Id., ¶ 46. Air traffic controller reports state that some victims appeared to be as young as 11 years old. Id., ¶ 51. Evidence also shows that when two of the victims…
…these documents. The window for authenticating the documents through depositions 7 Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9 of 42 has shut. Expert reports have been exchanged, so Ms. Giuffre’s…