…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH<…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH<…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH<…
…VIRGINIA L. GIUFFRE, Plaintiff, v. 15-cv-07433-RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X DEFENDANT’S MOTION FOR RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH<…
…OF SIGRID S. MCCAWLEY IN PLAINTIFF’S RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION FOR DEFENDANT’S RULE 37(b) &(c) SANCTIONS FOR FAILURE TO COMPLY WITH COURT ORDER AND FAILURE TO COMPLY WITH RUILE 26(a) I, Sigrid S…
…they would yield documents responsive to Ms. Giuffre’s requests and in such a way wherein responsive documents would not be “missed” as a result of Defendant’s behind-the-scenes maneuvering with the syntax of the search terms. Specifically…
…RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With …
…RWS GHISLAINE MAXWELL, Defendant. --------------------------------------------------X Declaration Of Laura A. Menninger In Support Of Defendant’s Motion For Rule 37(B) &(C) Sanctions For Failure To Comply With Court Order And Failure To Comply With …
…Repeated Disregard for this Court’s Order Supports An Adverse Inference Ms. Giuffre does not want to burden the Court with unnecessary briefing on a topic that has been argued multiple times. See Docket Entry 96 (Motion for Forensic Examination)…
…Epstein Estate. BACKGOUND Under Virgin Islands law, the CICO authorizes the USVI through its Attorney General to prosecute a civil action against any persons engaged in a pattern of criminal activity through association with any enterprise. 14 V.I.C…
…over 10,000 documents, but, remarkably, claims that not a single document - not one - is relevant to this litigation, and therefore produced nothing with respect to the search. I. FACTUAL BACKGROUND On October 27, 2015, Ms. Giuffre submitted her first…
…00069). Ms. Giuffre is aware of two email addresses that appear to be the email addresses Defendant used while Ms. Giuffre was with Defendant and Epstein, namely, from 2000 - 2002. Defendant has denied that she used those accounts to communicate…
…over 10,000 documents, but, remarkably, claims that not a single document - not one - is relevant to this litigation, and therefore produced nothing with respect to the search. I. FACTUAL BACKGROUND On October 27, 2015, Ms. Giuffre submitted her first…
…Kellen be directed to appear for her deposition; (2) that Ms. Kellen pay Ms. Giuffre’s costs and reasonable attorney’s fees associated with bringing this motion; (3) that Ms. Kellen be ordered to pay a civil penalty of $2500…
…over 10,000 documents, but, remarkably, claims that not a single document - not one - is relevant to this litigation, and therefore produced nothing with respect to - the search. I. FACTUAL BACKGROUND On October 27, 2015, Ms. Giuffre submitted her first…
…Defendant. The requests are narrowly tailored to the time frame related to this case, as the requested information concerns 1 Contemporaneous with the filing of this response to Defendant’s motion for a protective order regarding financial information, Ms. Giuffre…
…Adverse Inference (explaining numerous questions that Ms. Giuffre intends to ask Epstein as trial). Accordingly, Ms. Giuffre has served him with a trial subpoena, through Epstein’s legal counsel. Epstein’s, through counsel, now has filed a motion to quash…
…2 did not even request excerpts of the documents in which their names appear, let alone file objections to unsealing. Maxwell’s objections are inconsistent with the Court’s May 1, 2020 Order, the presumption of public access to documents…
…whether Ms. Giuffre was telling the truth about Ms. Maxwell’s involvement in sex trafficking, but whether attorneys representing her in a separate case had filed allegation on her behalf concerning Alan Dershowitz with due diligence. Under Fed. R. Civ…
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