giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…CASE AGAINST MS. MAXWELL ...................................................................... 15
III. PLAINTIFF’S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED
WITH EXTRA TIME ........................................................................................................ 18
1. Plaintiff’s Rule 26 Re…
giuffre-maxwell
1320-28
32 pg
…CASE AGAINST MS. MAXWELL ...................................................................... 15
III. PLAINTIFF’S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED
WITH EXTRA TIME ........................................................................................................ 18
1. Plaintiff’s Rule 26 Re…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.19_2
32 pg
…THIS CASE AGAINST MS. MAXWELL ................................................................ ...... 15
III. PLAINTIFF 'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED
WITH EXTRA TIME ................................................................................................ ........ 18
1. Plaintiffs Rule …
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…TIME
1. Plaintiff’s Rule 26 Revolving Door
Plaintiff’s army of lawyers (who collectively have been litigating matters related to
Jeffrey Epstein since 2008) served their Rule 26 initial disclosures on November 11, 2015.
Those disclosures listed 94 individual…
…not us that's
[00:49:25] holding the revolving door open into the
[00:49:28] banks and the military-industrial
[00:49:30] complex
[00:49:33] and you know the darker parts of this
[00:49:35…
…After being
[01:41:37] a regulator in France, mind you,
[01:41:39] revolving doors always revolving.
[01:41:41] Recruited at the end of 2008, Mcronone
[01:41:43] was promoted to a partner with the bank
[01…
DataSet-9
EFTA00705393
25 pg
…Instead, we opened the door for President Trump, who found an audience that
could be easily misled.
The news media's spectacular failure to get the election right has made it only easier for many
conservatives to ignore anything that…
DataSet-9
EFTA00087203
17 pg
…of the Rule 702 and Daubert inquiry is "fit," which asks
"whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it
will aid the jury in resolving a factual dispute." Alto v…
DataSet-9
EFTA00582880
11 pg
…6); Epstein sought to avoid liability by "employing the extraordinary
financial resources at his disposal to intimidate his victims into abandoning their legitimate
claims or resolving these claims for substantially less than their just value" (id.); Edwards'
conduct in the…
DataSet-9
EFTA00722411
16 pg
…2010, Marsigliano went to Epstein's mansion at 9 East 714
Street, and he knocked on the door. An employee of Epstein who identified himself as
"Mark" answered the door and informed Mr. Marsigliano that Epstein was "not home'
before…
DataSet-9
EFTA00068501
17 pg
…of the Rule 702 and Daubert inquiry is "fit," which asks
"whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it
will aid the jury in resolving a factual dispute." Alto v…
DataSet-9
EFTA00089904
17 pg
…of the Rule 702 and Daubert inquiry is "fit," which asks
"whether expert testimony proffered in the case is sufficiently tied to the facts of the case that it
will aid the jury in resolving a factual dispute." Alto v…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…beautiful was a
bias for a blooming business relationship between him and Jeffrey.
After an explicit session of Jeffrey’s vulgar pilgrimage into my
body, we were interrupted by a knock at the door by Jeffrey’s good
friend, Alan…
DataSet-9
EFTA00295177
24 pg
…in its sole discretion, shall accept the Aircraft as is,
accept the Aircraft subject to Seller's resolving any Inspection Discrepancies (as hereinafter
defined), or reject the Aircraft by delivering to Seller a Preliminary Acceptance Certificate in the
Form of…
DataSet-9
EFTA00311105
24 pg
…in its sole discretion, shall accept the Aircraft as is,
accept the Aircraft subject to Seller's resolving any Inspection Discrepancies (as hereinafter
defined), or reject the Aircraft by delivering to Seller a Preliminary Acceptance Certificate in the
Form of…
DataSet-9
EFTA00300122
24 pg
…in its sole discretion, shall accept the Aircraft as is,
accept the Aircraft subject to Seller's resolving any Inspection Discrepancies (as hereinafter
defined), or reject the Aircraft by delivering to Seller a Preliminary Acceptance Certificate in the
Form of…
DataSet-9
EFTA01099088
21 pg
…however, Judge Stapleton may have shown prescience
to the evolving "Twontbly/labar line of cases requiring rules of pleading removing legal
conclusions and requiring the remaining factual allegations to "plausibly suggest" them. If
Plaintiffs suggest a realistic basis for believing…
DataSet-9
EFTA00138988
1 pg
…mate (UM TartaglioneW78514-054)was at the door stating UM Epslein.Jefferya76318-054 had attempted to
hang himself:I-Wept a visual while SIC) grabbed the door keys and called for assistance. After Secunng UM Tartaghonee /8514.054 and removing
…
DataSet-9
EFTA00040960
2 pg
…78514.054)was at the door stating UM Epsten.Jeflerya76318.054 had
attempted to
hang himself. I kept a visual while S/0 Silva grabbed the door keys and called or assistance. A rSecur…
DataSet-9
EFTA01226814
230 pg
…54
Personnel Credentials Tab Definitions 55
Credentials Tab Tasks 59
Adding an Access Card 61
Adding a PIN-Only Access Credential …
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