…at 21:53, "Ross Gow" wrote: Ghislaine I believe the next 18hrs is the best chance we have to leverage some transparency advantage on this. MoS first then Sunday Times. Otherwise we lose any chance of ownership of the narrative…
…"G Maxwell" wrote: I am out of my depth to understanding defamation and other legal hazards and don't want to end up in a law suit aimed…
…at 8:00 PM, Brad Edwards wrote: > > Just to be clear, I specifically did not confer with anyone about this issue. > > A few weeks ago Jeff told me they had not received search…
…this Motion. Based on the conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the Second Set of Discovery Requests. PRELIMINARY STATEMENT Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation…
…couple days. On Monday, June 13, 2016, the following business day, the undersigned wrote again requesting a meet and confer call, again offering the next couple days to have the call. See Schultz Decl. at Exhibit 2. Again, the undersigned…
…this Motion. Based on the conferral, Plaintiff’s counsel wrote a letter declining to supplement any of the responses to the Second Set of Discovery Requests. PRELIMINARY STATEMENT Plaintiff has brought a lawsuit alleging Ms. Maxwell defamed her. The defamation…
…22 THE COURT: Yes. I think I picked up on that. 23 MR. PAGLIUCA: These are the lawyers that wrote the 24 false allegations. 25 THE COURT: I think I picked up on that, too. SOUTHERN DISTRICT REPORTERS, P.C. …
…cv-07433-LAP Document 441 Filed 09/21/16 Page 14 of 18 APPENDIX A O n September7 ,20 16,M s.Giu ffre wrote to D efend antwithasu mmary and certification of M s.Giu ffre’s d iscovery…
…s unpublished and un-dated book manuscript, The Billionaire Playboys’ Club, she writes: “The next big dinner party on the island had another significant guest appearance being the one and only, Bill Clinton. He is the only president in the…
…After receiving Defendant’s production of the police reports pursuant to Rule 26 disclosures, Plaintiff wrote a letter requesting the Documents be designated Confidential. Counsel for Ms. Maxwell promptly responded that the documents are publicly available and therefore should not…
…like, a message system between him, the houses, the employees, his friends. They would write a message on the computer. There was no email at that time. Q. Okay. So what computer would you use? A. My computer in my…
…Ms. Maxwell, presumably to include the very email that forms the subject of this motion. Plaintiff will have a full and fair opportunity to question him under oath regarding the email that he wrote to Ms. Maxwell. Finally, Plaintiff claims…
…On May 20, 2016, counsel for Ms. Giuffre wrote Mr. Pagliuca a letter, explaining in detail both her good faith and statutory basis upon which she made her confidentiality designation, as various state statutes protect the confidentiality of these materials…
…company. Plaintiff’s counsel, Meredith Shultz, wrote on May 17, 2016, regarding an account of Plaintiff’s (that she claims she cannot access but for which relevant and responsive emails were located on her computer): - “Regarding her live.com address…
…this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? …
…this. 15 A. Okay. We've been together 16 almost a year. 17 Q. And what is your current 18 occupation? 19 A. I'm a writer. 20 Q. And what do you write? 21 A. Just stuff, you know? …
…did not read the articles published by Sharon Churcher about your stories to Sharon Churcher? A: I have read some articles about what Sharon Churcher wrote. And a lot of the stuff that she writes she takes things from my…
…2015, while the media maelstrom generated by Plaintiff’s false claims continued to foment, he wrote: “You have done nothing wrong and I would urge you to start acting like it. Go outside, head high, not as an escaping convict…
…MR. CRITTON: Form. 10 A No. The main house. 11 THE WITNESS: At that time or what time? 11 a And do you know who wrote the names? 12 BY MR. EDWARDS: ~~~ 12 A No, sir. 13 a Yeah …
…Ms. Ransome at her deposition, she possesses other responsive communications. For example, she testified that she wrote to the NY Post reporter, Maureen Callahan, in an attempt to sell her story to the media, in or about October 2016. Pottinger…