…memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name.” Plaintiff is asking defendant to Meredith Schultz Paul Cassell July 29, 2016 Page 2 produce…
…mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name.” Plaintiff is asking defendant to Case 1:15-cv-07433-LAP Document 1199-5 Filed 01…
…and Treasurer—knowingly participated in the Epstein Enterprise and facilitated the trafficking and sexual servitude of underage girls and young women by providing the secluded properties at, from, or to which Epstein and his associates could transport, transfer, maintain, isolate…
…501, 510 (1984)). Plaintiff ignores this expressly-condoned countervailing factor and instead relies on cases generally concerning pretrial publicity and motions to transfer venue.4 Plaintiff shrugs off concerns about the fairness of Ms. Maxwell’s criminal trial as “vague…
…Div. 2016). 16. All bank statements, credit card statements, money transfer records, or other statements from any financial institution in Your name, in whole or in part, for the years 2006-2007. 14 RESPONSE: In addition to the Preliminary Statement…
…or not), memoranda, mobile phone agreements, wire transfer receipts, or any other document that concerns Plaintiff in any way, whether or not they reference her by name. Defendant is clearly withholding Barden documents that are responsive to Ms. Giuffre’s…
…Div. 2016). 16. All bank statements, credit card statements, money transfer records, or other statements from any financial institution in Your name, in whole or in part, for the years 2006-2007. 14 Case 1:15-cv-07433-LAP…
…Div. 2016). 16. All bank statements, credit card statements, money transfer records, or other statements from any financial institution in Your name, in whole or in part, for the years 2006-2007. 14 RESPONSE: In addition to the Preliminary Statement…
…41 Produce all records pertaining to the acquisition, transfer and sale of all securities by You or on Your behalf from January 2015 to the present, such records to include any and all information relative to gains or losses realized…
…of January 1, 2015 through the present, Ms. Maxwell has had no payments made or things of value transferred to her, including loans, by Jeffrey Epstein or any entity or person affiliated with or controlled by him.” Simply put, Ms…
…January 1, 2015. 5. Identify all payments made or things of value transferred to you by Jeffrey Epstein, directly or indirectly or through any entity or person affiliated with or controlled by Epstein, from 1992 through the present, and if…
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