…Court to Direct Defendant To Disclose All Individuals To Whom Defendant Has Disseminated Confidential Information. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of May 18, 2016, Correspondence from Jeff Pagliuca to Meredith Schultz. 4…
…In Support of Motion to Reopen Defendant’s Deposition Based on Late Production of New, Key Documents. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from May 18, 2016, Deposition of Johanna Sjoberg. …
…s Response in Opposition to Defendant’s Motion in Limine to Exclude in Toto Certain Deposition Designated by Plaintiff for Use at Trial. 3. - Attached hereto as Sealed Exhibit 1 is a true and correct copy of February 9, 2017…
…for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of Rinaldo Rizzo. 4…
…Declaration in Support of Plaintiff’s Motion to Compel Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from June 1, 2016…
…Testimony from Jeffrey Epstein for Purpose of Obtaining an Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of …
…Declaration in Support of Plaintiff’s Motion to Compel Communication All Work Product and Attorney Client Communications with Philip Barden. 3. Attached hereto as Sealed Composite Exhibit 1 is a true and correct copy of Defendant’s February 9, 2016…
…b) &(c) Sanctions for Failure to Comply with Court Order and Failure to Comply with Rule 26(a). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from the May 18, 2016 Deposition of . …
…Declaration in Support of Plaintiff’s Motion to Compel Data from Defendant’s Undisclosed Email Account and for Adverse Inference Instruction. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of Excerpts from June 1, 2016…
…2016, Order. 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of September 23, 2016, Transmittal Email serving Laura Menninger. 5. Attached here to as Sealed Exhibit 3 is a true and correct copy of a…
… Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of . I declare under penalty of perjury that the foregoing is true and correct. Case 1:15-cv-07433-LAP Document 690 Filed 03/03/17 Page…
…Testimony of Jeffrey Epstein. 3. Attached hereto as Sealed Composite Exhibit 1 are true and correct copies of . I declare under penalty of perjury that the foregoing is true and correct. …
…of Virginia Giuffre in an Unrelated Case. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of . I declare under penalty of perjury that the foregoing is true and correct. …
…Defendant To Disclose All Individuals To Whom Defendant Has Disseminated Confidential Information. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached hereto as Sealed Exhibit 2 is a true and correct copy of …
…and January 26, 2021 (ECF No. 1193), Plaintiff files the documents ordered unsealed listed in Exhibit F to Defendant’s Reply Memorandum of Law in Further Support of Objections to Unsealing Sealed Materials Related to Docket Entries 231, 279, 315…
…Support of Plaintiff’s Reply in Support of Plaintiff’s Motion to Compel (DE 345). 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of November 10, 2015, Correspondence from Ross Gow to Ghislaine Maxwell. 4…
…Plaintiff. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of FBI 302 Statement. I declare under penalty of perjury that the foregoing is true and correct. /s/ Bradley Edwards Bradley Edwards,…
…to Jeffrey Epstein Plea and Non-Prosecution Agreement and Sex Offender Registration. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of . 4. Attached hereto as Sealed Composite Exhibit 2 are true and correct copy of …
…Plaintiff’s Reply to Motion to Compel Communication All Work Product and Attorney Client Communications with Philip Barden. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of January 6, 2017 Declaration of Philip Barden. 4…
…to Motion to Compel Communication All Work Product and Attorney Client Communications with Philip Barden. 3. Attached hereto as Sealed Exhibit 1 is a true and correct copy of 4. Attached hereto as Sealed Composite Exhibit 2 I declare under…
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