…164, 172, 199, & 230 Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 2 of 24 TABLE OF CONTENTS PRELIMINARY STATEMENT .................................................................................................... 1 ARGUMENT ..........................…
…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…
…e.g., Plaintiff’s Statement of Undisputed Facts in Response to Defendant’s Motion for Summary Judgment at 4-27 (recounting details of Epstein’s and Defendant’s sex trafficking and sex abuse conspiracy); see also Plaintiff Giuffre’s Reply…
…Lauderdale, FL 33301 (954) 356-0011 Case 1:15-cv-07433-LAP Document 561 Filed 01/27/17 Page 2 of 22 TABLE OF CONTENTS …
…term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers on Defendant’s 4 defamatory statements made about Ms. Giuffre…
…term (either in reality or in the position she took on Friday) is evidence of Defendant’s continued bad faith and complete avoidance of her discovery obligations. The case centers on Defendant’s 4 defamatory statements made about Ms. Giuffre…
…records, and 10 days before the end of fact discovery in this case, Ms. Maxwell has learned of at least five additional doctors who have treated Plaintiff since the time of the alleged defamatory statement: Dr. Lightfoot, Dr. Geiger, Dr…
…bad faith and complete avoidance of her discovery obligations. The case centers on Defendant’s 4 Case 1:15-cv-07433-LAP Document 1327-19 Filed 01/05/24 Page 5 of 21 defamatory statements made about Ms. Giuffre…
…records, and 10 days before the end of fact discovery in this case, Ms. Maxwell has learned of at least five additional doctors who have treated Plaintiff since the time of the alleged defamatory statement: Dr. Lightfoot, Dr. Geiger, Dr…
…records, and 10 days before the end of fact discovery in this case, Ms. Maxwell has learned of at least five additional doctors who have treated Plaintiff since the time of the alleged defamatory statement: Dr. Lightfoot, Dr. Geiger, Dr…
…Ms. Maxwell has learned of at least five additional doctors who have treated Plaintiff since the time of the alleged defamatory statement: In each case, documents relating to these doctors were not provided until after their identities became known through…
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