…Maxwell defendants, take no 14 position on our application. Judge Koeltl has expressed a 15 willingness to consider the information that we are seeking by 16 way of this modification. 17 THE COURT: Incidentally, as I understand it, what we…
…has already asserted objections on her own behalf to many of the documents that will be at issue. In any event, Plaintiff is willing to confer with Maxwell in good faith to address ways to alleviate her burden. For example…
…4, 2016, Plaintiff represented in Response that she “is willing to produce the Settlement Agreement and all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from Jeffrey Epstein for its disclosure.” Doc. #78 at 15. Indeed…
…July 13, 2016 8:22 PM To: Jeff Pagliuca Subject: Fwd: Your motions Jeff, Look I'm not going to be dragged into these nonsense emails. I'm willing to help clear up miscommunication if that indeed occurred. However, I…
…McCawley indicated on the record that she did not oppose an adjournment. In Plaintiff’s Reply, she indicated that she would be willing to make an additional attempt to confer before rescheduling the hearing on the Motion. Reply at 3…
…Ms. Giuffre has been asking for April dates for this deposition since March. After repeated requests, counsel for Defendant was only willing to make Defendant available for deposition the first week of May, on the eve of trial. This motion…
…dkt. no. 1044 in 15 Civ. 7433].) Critically, the agreed-upon unsealing procedure can only work as intended if non-parties are willing to participate. Handing over to Mr. Dershowitz all of the materials from Maxwell, which would necessarily include…
…no purchase price for the ticket, because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
…no purchase price for the ticket, because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis.” Defendant’s Combined Motion at 7. Any suggestion of “fabrication…
…for the second time, Mr. Dershowitz has demonstrated that he is willing to reveal - and misrepresent - confidential information in his effort to win his battle in the court of public opinion. This time, he did so in deliberate and brazen…
…maybe what about 7 you? 8 And I was at a point in life, I was super 9 spontaneous and willing to skip school. 10 So she said, Come to my house, come in my 11 car and check it…
…2005, I was contacted by Atty . Gus Fronstin , who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested…
…2005, I was contacted by Atty . Gus Fronstin , who advised he was willing to assist with the investigation. Atty. Fronstin advised he would try to have his client , Jeffrey Epstein available to be interviewed. I explained I would be interested…
…As indicated in her March 14 correspondence, Ms. Maxwell’s counsel is willing to discuss her ESI discovery protocols, but only if such discussion begins at a rational starting point for a single-plaintiff, single-defendant case such as this…
…because the people who want the testimony are willing to front the cost of the litigation either on a contingency or pro-bono basis. “Evidence tending to show a witness's bias or motive to fabricate testimony or evidence presented…
…flat refusal to discuss her ESI protocols (“ [w]e do not believe we have an obligation to describe for your [sic] our document search methods”), Defendant now acknowledges in her Response brief some willingness to do so.3 Yet, still…
…Richard Branson having sexual intercourse with my friend. I will be more then willing to swear under oath and testify in court over these sex tapes. It will break your heart into a million tiny pieces Maureen when you watch…
…in Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and willing to say anything to avoid her deposition. Similarly, the Court is familiar with the long (and still on-going) effort of Ms. Giuffre…
…wrote in her responses and objections, that she is willing to produce the Settlement Agreement and all documents concerning the Settlement Agreement if Defendant gets a waiver of liability from Jeffrey Epstein for its disclosure. Defendant has a joint defense…
…etc. B. Plaintiff Refuses To Provide Her Residence, Domicile And Address Where She Lived During Alleged “Defamation.” Plaintiff claims she was willing to, and has already, responded to Interrogatory 1 and complied with the requirement of Local Rule 26.1…
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