giuffre-maxwell
gov.uscourts.nysd.447706.1295.8
9 pg
…In addition, Defendant set her deposition for Friday,
February 17, 2017 giving this witness less than two (2) weeks notice to make travel
arrangements from Europe. Despite these obstacles, non-party Ransome complied by producing
over 235 pages of highly…
giuffre-maxwell
gov.uscourts.nysd.447706.751.10
4 pg
…want, for the record to refer to the events that have taken place in the last three weeks. And I
just wish to reiterate and to reaffirm the statements which have already been made on my behalf by Buckingham
Palace…
giuffre-maxwell
gov.uscourts.nysd.447706.199.0
8 pg
…30, 2016, and, therefore, requests an additional four (4) weeks to complete these
depositions. She requests the deposition deadline be extended to July 30, 2016. The requested
relief would not disturb the trial date.
BACKGROUND
As the Court knows, this…
giuffre-maxwell
gov.uscourts.nysd.447706.648.0
4 pg
…parties propose the following schedule:
The jury trial scheduled for March 13, 2017 is rescheduled to begin on May 15, 2017 and
is anticipated to last four weeks;
Motions in Limine/other motions shall be filed by March 3, 2017…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…that they should not be allowed to seek
5 confidential information in this case.
6 Your Honor will remember that I was before you a
7 couple of weeks ago again trying to get the deposition of the
8 defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…2016 – 15 months after the supposed defamation, 8 months after
filing suit, 8 weeks after the defense requested the records, 2 weeks after the Motion to Compel
was filed, and 1 day after she informed the Court that she had…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…should be in person; she chose to move to Australia from
Colorado during the pendency of this case and has been in the US for weeks attending witness
depositions and other litigation matters by her own choosing. Deposition by videoconference…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.8_1
3 pg
…I specifically did not confer with anyone about this issue.
>
> A few weeks ago Jeff told me they had not received search terms and if I remember correctly said that it would
take 10 days after receiving the…
giuffre-maxwell
gov.uscourts.nysd.447706.1079.0
4 pg
…2, 2020--that is, three weeks prior to the Court’s
July 23 decision to unseal the materials at issue. To the extent
that they relate to the to the Court’s balancing of interests in
the unsealing process, the…
giuffre-maxwell
gov.uscourts.nysd.447706.111.2
5 pg
…2:13-cv-06329-LDW-AKT Document
49 111-2 Filed 04/21/16
Filed 08/25/14 Page 2Page
of 4 3 of 5 #: 520
PageID
Th…
giuffre-maxwell
gov.uscourts.nysd.447706.515.0
12 pg
…public denials by such individuals so that she could
lodge defamation claims against them. Indeed, just three weeks earlier, an accuser of Bill Cosby filed for defamation
based his then recent denials of a 2005 sexual assault. See CBS News…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…should be in person; she chose to move to Australia from
-
Colorado during the pendency of this case and has been in the US for weeks attending witness
depositions and other litigation matters by her own choosing. Deposition by videoconference…
giuffre-maxwell
gov.uscourts.nysd.447706.1100.0
16 pg
…Individual Practices in Criminal Cases, counsel
initiated a conferral with the U.S. Attorney’s Office over the weekend concerning a
modification of the Protective Order to share the information with this Court and the Second
Circuit. Barring agreement, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.40
30 pg
…that they should not be allowed to seek
5 confidential information in this case.
6 Your Honor will remember that I was before you a
7 couple of weeks ago again trying to get the deposition of the
8 defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.160.0
12 pg
…See McCawley Decl. at Exhibit 4
Affidavit of Douglas G. Mercer, Chief Investigator Alpha Group. Those efforts have continued
for weeks, and included over sixteen (16) attempts to personally serve Epstein, including as
recently as May 18, 2016, at which…
giuffre-maxwell
gov.uscourts.nysd.447706.235.1
31 pg
…that they should not be allowed to seek
5 confidential information in this case.
6 Your Honor will remember that I was before you a
7 couple of weeks ago again trying to get the deposition of the
8 defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.136.0_2
29 pg
…that they should not be allowed to seek
5 confidential information in this case.
6 Your Honor will remember that I was before you a
7 couple of weeks ago again trying to get the deposition of the
8 defendant…
giuffre-maxwell
gov.uscourts.nysd.447706.269.0
19 pg
…2016 – 15 months after the supposed defamation, 8 months after
filing suit, 8 weeks after the defense requested the records, 2 weeks after the Motion to Compel
was filed, and 1 day after she informed the Court that she had…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…they
preferred. In a judgment delivered on 8th November 2002 HH Judge Weeks QC held that
that use was an infringement of the copyright in the 1998 original and a breach of
confidentiality, and he ordered an inquiry as to…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…Counsel
for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that
offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that
deposition in the Virgin Islands…
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