EXHIBIT K From: Richards, Jason R. To: Robert Giuffre Subject: RE: Hi There Date: Wednesday, August 27, 2014 10:44:32 AM Hi Jenna, My suggestion is for you to do a Freedom of Information Act request (www.foia.gov…
…Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTIONS BOIES, SCHILLER & …
…3 To: Marianne Strong[[email protected]] From: Virginia Giuffre Sent: Fri 2/21/2014 1:17:22 PM Importance: Normal Subject: Re: NYC Post Inquiry re : Jeffrey Epstein Received: Fri 2/21/2014 1:17:22 PM Dearest marianne, …
…No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S CONSOLIDATED REPLY IN SUPPORT OF MOTIONS TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTIONS AND IMPROPER CLAIM OF PRIVILEGE …
…L. Giuffre, Plaintiff, Case No.: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTION AND IMPROPER CLAIM OF PRIVILEGE Plaintiff Virginia Giuffr…
…YORK --------------------------------------------------X .... ........................................... VIRGINIA L. GIUFFRE, Plaintiff, v. …
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…McCawley; Jeff Pagliuca; Brad Edwards; Paul Cassell ([email protected]) Subject: RE: Conferral regarding forensic search Follow Up Flag: Follow Up Flag Status: Flagged Laura, Please see my additions in-line, in black, below to your email sent yesterday…
…11 I. PROFESSOR DERSHOWITZ SHOULD BE PERMITTED TO INTERVENE UNDER FEDERAL RULE OF CIVIL PROCEDURE 24(B) ..............................11 A. There Is Significant Overlap Between the Subject Matter of the Original Action and This Moti…
…I, , declare as follows: 1. I am an attorney at law duly licensed in the District of Columbia. 2. I am familiar generally with the subject matter of this action, No. 15-cv-07433-RWS (S.D.N.Y.). 3…
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…Emeritus, at Harvard Law School, where I taught criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have also represented numerous individuals accused of crimes over the course of my career. I am…
…v. Ghislaine Maxwell, Defendant. ________________________________/ PLAINTIFF, VIRGINIA GIUFFRE’S REPLY IN RESPONSE TO DEFENDANT’S SUPPLEMENTAL MEMORANDUM OF LAW IN RESPONSE TO PLAINTIFF’S MOTION TO COMPEL THE PRODUCTION OF DOCUMENTS SUBJECT TO IMPROPER OBJECTIONS …
…33.3. Defendant has served interrogatories that are in direct violation of that Rule because the interrogatories are not “restricted to those seeking names of witnesses with knowledge of information relevant to the subject matter of the action, the computation…
…P. 32(a)(8). ...............................................................4 A. The Florida State Case Did Not Involve the Same Subject Matter. ...........................5 B. The Florida State Case Did Not Involve the Same Parties.........................................6 II. THE COURT SH…
…Borja, declare as follows: 1. I am an attorney at law duly licensed in the District of Columbia. 2. I am familiar generally with the subject matter of this action, No. 15-cv-07433-RWS (S.D.N.Y.). 3…
…Emeritus, at Harvard Law School, where I taught criminal law, legal ethics and other subjects for 50 years. As a criminal defense attorney, I have also represented numerous individuals accused of crimes over the course of my career. I am…
…and abuse while she was a minor child. Defendant Maxwell not only facilitated that sexual abuse but, most recently, wrongfully subjected Giuffre to public ridicule, contempt and disgrace by, among other things, calling Giuffre a liar in published statements with…
…Las Olas Boulevard, Suite 1200 Miami, Florida 33301 Tel: (954) 356-0011 Email: [email protected] Plaintiff - information regarding Defendant, Ghislaine Maxwell’s conduct that is the subject of this action 2. Ghislaine Maxwell c/o…
…1, New York Daily News, April 7, 2015. Defendant has subjected Jane Doe No. 3 to horrific public attacks including publicly calling her a “prostitute” and a “bad mother” to her three minor children. See Exhibit 2, Local 10 News…
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