Found 105 results for “statement” in 429ms

gov.uscourts.nysd.447706.1247.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1247.0 25 pg

…144, 147, 171 AND 183’S OBJECTIONS TO UNSEALING Case 1:15-cv-07433-LAP Document 1247 Filed 03/18/22 Page 2 of 25 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................1 ARGUMENT .........…

gov.uscourts.nysd.447706.1078.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.1 8 pg

…behalf of our client, Ghislaine Maxwell, we write to request that the Court enter an order prohibiting the Government, its agents and counsel for witnesses from making extrajudicial statements concerning this case. Although Ms. Maxwell is presumed innocent, the Government,…

gov.uscourts.nysd.447706.1325.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.19 20 pg

…Ghislaine Maxwell, by and through her undersigned counsel, hereby responds to Plaintiff’s First Set of Interrogatories (the “Interrogatories”). PRELIMINARY STATEMENT AND GENERAL OBJECTIONS 1. This response is made to the best of Ms. Maxwell’s present knowledge, information and…

gov.uscourts.nysd.447706.562.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.562.1 13 pg

…Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre…

gov.uscourts.nysd.447706.1328.23.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.23 22 pg

…York and transferring the money outside the jurisdiction. Accordingly, Defendant’s motion for a protective order should be denied.1 I. PRELIMINARY STATEMENT As recounted by Defendant (DE 370 at 1-3), Ms. Giuffre has served discovery requests on Defendant…

gov.uscourts.nysd.447706.1.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1.0 12 pg

…Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre…

gov.uscourts.nysd.447706.24.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.24.1 13 pg

…Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise upon information and belief: NATURE OF THE ACTION 1. This suit arises out of Defendant Maxwell’s defamatory statements against Plaintiff Giuffre. As described below, Giuffre…

gov.uscourts.nysd.447706.235.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.235.2 4 pg

…May 3rd, please provide the following documents on or before April 27th, 2016.  All documents withheld on the basis of the “public interest privilege,” other than Plaintiff’s actual statements to any law enforcement agency, which are to be…

gov.uscourts.nysd.447706.57.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.57.1 26 pg

…was that on the day of the accident a brief report was made to the railway inspectorate, soon afterwards a joint internal report (" the joint inquiry report") was prepared incorporating statements of witnesses, which was also sent to the inspectorate…

gov.uscourts.nysd.447706.363.11.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.11 40 pg

…Schiller & Flexner, which also represents Virginia Giuffre, issued this statement earlier today: “Virginia Giuffre was not a party to that [defamation] lawsuit and was not a party to the settlement. We continue to represent Ms. Giuffre in other litigation and…

gov.uscourts.nysd.447706.1218.43.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1218.43 4 pg

…but two statements saying Prince Andrew is completely innocent of all the accusations. VICTORIA MURPHY: They issued one statement initially in response to the allegations that Prince Andrew had had sex with an underage minor and that was what they…

gov.uscourts.nysd.447706.31.0_1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.31.0_1_1 22 pg

…by the defendant with a certain 12 level of culpability and resulting injury. Depending on the 13 context of the words, the content of the statement, the 14 relationship of the speaker and the listener, depending on the 15 time…

gov.uscourts.nysd.447706.1090.46.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1090.46 14 pg

…concerning Plaintiff’s medical and mental health treatment, (b) her unjustifiable refusal to answer questions related to statements the media “got wrong,” (c) material edits to her deposition testimony through her errata sheet. Plaintiff did not address her newly disclosed…

gov.uscourts.nysd.447706.276.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.276.0_1 35 pg

…the three that we had alternative service for, and then we have 12 Mr. Ross GOw, who was the defendant's agent who issued the 13 defamatory statement, Mr. Brunel -- 14 THE COURT: How much time do you want? 15 …

gov.uscourts.nysd.447706.1201.17.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.17 12 pg

…Ms. Giuffre’s motion should be granted. I. PRELIMINARY STATEMENT Defendant begins her brief with snippets of her self-serving testimony. As the Court is aware, all of this testimony is directly contradicted by the myriad of other witnesses in…

gov.uscourts.nysd.447706.1328.35.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.35 10 pg

…irrelevant to this lawsuit whether Ms. Maxwell engaged in consensual, adult sexual activities with women. There is no allegedly defamatory statement that has anything to do with Ms. Maxwell’s private adult sex life. It is an abuse of this…

gov.uscourts.nysd.447706.1320.40.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.40 19 pg

…Ms. Maxwell is the Defendant and may have knowledge concerning matters at issue, including the events of 1999-2002 and the publication of statements in the press in 2011-2015. 2. Virginia Lee Roberts Giuffre c/o Sigrid S. McCawley…

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