Found 37 results for “willing” in 304ms

gov.uscourts.nysd.447706.40.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.40.0 8 pg

…delay, Ms. Giuffre stated that she would be willing to “agree to a reasonable Protective Order being in place in this case” and attached a redlined version of Defendant’s proposed Protective Order. 1 See McCawley Decl. at Exhibit 4…

gov.uscourts.nysd.447706.1328.40.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.40 3 pg

…I certainly do feel that down the long, winding road, your case has merit! God willing that it puts that piece of human scurr back behind bars! Should you win the day, yes, T do believe that you can create…

gov.uscourts.nysd.447706.1206.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1206.2 23 pg

…Civ. P. 1). “If protective orders were easily modified . . . parties would be less forthcoming in giving testimony and less willing to settle their disputes.” S.E.C. v. TheStreet.Com, 273 F.3d 222, 230 (2d Cir. 2001). In particular…

gov.uscourts.nysd.447706.824.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.824.0_2 47 pg

…when it gets produced in this case. I 22 am not willing to accept plaintiff's representations on this as 23 to what it is or isn't. I've never had the opportunity to 24 question or cross-examine…

gov.uscourts.nysd.447706.1328.22.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.22 22 pg

…CONTACT WITH JOSHUA BUNNER AND THIS TIME I WAS SUCCESSFUL. I ASKED JOSH IF HE "WO)JLD BE WILLING TO SPEAK WITH ME IN REGARDS TO AN ONGOING SHERIFF'S OFFft:~~f?J:NVESTIGATION AND HE AGREED TO DO THIS…

gov.uscourts.nysd.447706.1296.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.12 29 pg

…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…

gov.uscourts.nysd.447706.1296.9.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.9 29 pg

…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…

gov.uscourts.nysd.447706.1328.21.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.21 19 pg

…the possibility that soin'e"""a'rhis friends might have abused his girlfriend and he wanted me to know that he was willing to cooperate in anyway that he c o u ~ t to the bottom of this incident…

gov.uscourts.nysd.447706.1332.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1332.7 29 pg

…No other girl would be there 8 Case 1:15-cv-07433-LAP Document 1332-7 Filed 01/08/24 Page 13 of 29 Key Testimony Transcript Citation willingly just to have sex with Jeffrey.) Victoria Secret Ransome Dep…

gov.uscourts.nysd.447706.562.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.562.2 29 pg

…defend himself against charges of gross wrongdoing, Dershowitz followed his own prescription and took his defense to the court of public opinion where he had an audience willing to ignore both law and facts. The lawyer victims of Dershowitz's…

gov.uscourts.nysd.447706.1328.23.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1328.23 22 pg

…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…

gov.uscourts.nysd.447706.78.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.78.0 30 pg

…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…

gov.uscourts.nysd.447706.1137.15_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.15_2 41 pg

…requesting an opportunity to take his deposition: Dear Mr. Dershowitz: Statements attributed to you in the public media express a willingness, indeed a strong desire, to submit to questioning under oath regarding your alleged knowledge of Jeffrey Epstein's extensive…

gov.uscourts.nysd.447706.1334.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1334.1 29 pg

…girl would be there 8 Case 1:15-cv-07433-LAP Document 1334-1 1332-7 Filed 01/08/24 Page 13 of 29 Key Testimony Transcript Citation willingly just to have sex with Jeffrey.) Victoria Secret …

gov.uscourts.nysd.447706.20.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.20.0 26 pg

…at a high-profile wedding in Rhinebeck, New York, confirming the suspicion that she was indeed still in the country and willing to say virtually anything in order to avoid her deposition. See Decl. of Sigrid McCawley at Composite Exhibit…

gov.uscourts.nysd.447706.99.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.99.0 22 pg

…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…

gov.uscourts.nysd.447706.363.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.363.0 18 pg

…Moreover, Ms. Giuffre’s willingness to sit for press interviews undermines any suggestion she might make that she has an ongoing interest in keeping her allegations of sexual abuse private. This Case, My Involvement as a Witness, and My Discovery…

gov.uscourts.nysd.447706.898.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.898.0 4 pg

…fact that “the names of the minor victims were already in the public record, and the record indicates that the victims may have been willing to testify despite the presence of the press,” would presumably have weighed against closure. Id…

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