1320-28.pdf

"VIRGINIA L. GIUFFRE, Plaintiff v. GHISLAINE MAXWELL, Defendant"

"Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Combined Response... Laura A. Menninger"

"Defendant Ghislaine Maxwell (“Ms. Maxwell”) files this Combined Response... Jeffrey S. Pagliuca"

"Ms. Sharon Churcher, Plaintiff’s friend, advocate"

"UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK... GHISLAINE MAXWELL, Defendant."

"Plaintiff’s Complaint... initial Rule 26 disclosures served on November 11, 2015"

"Ms. Maxwell will be unduly prejudiced without sufficient additional time to (a) secure any witnesses"

"already has sued Glenn Dubin, Epstein’s friend"

"Mr. Rizzo was deposed on June 14 and he has nothing to do with the remaining depositions."

"already has sued Glenn Dubin, Epstein’s friend"

"he was the one who initiated contact with Brad Edwards after reading about the lawsuit"

"President Clinton first appeared on Plaintiff’s Third Revised Rule 26 Disclosures two weeks ago on June 1."

"basis of this suit... She referenced him repeatedly by name in the Complaint filed on September 21, 2015."

"she directed her agent, Ross Gow, to attack Giuffre’s honesty and truthfulness"

"Emmy Taylor, Ghislaine’s blonde British assistant"

"In one article, authored by Sharon Churcher... DAILY MAIL (Mar. 5, 2011)"

"Former FBI Director Louis Freeh submitted a report wherein he concluded that President Clinton did not, in fact travel to, nor was he present on, Litt"

"forced to personally serve the Defendant’s former boyfriend, employer, and co-conspirator"

"forced to personally serve the Defendant’s former boyfriend, employer, and co-conspirator"

"forced to personally serve the Defendant’s former boyfriend, employer, and co-conspirator"

"Mr. Weinberg promptly responded to Ms. McCawley’s inquiries. ... offering to let her know regarding acceptance of service on April 7"

"Mr. Epstein is a resident of the U.S. Virgin Islands."

"Plaintiff’s own counsel have strenuously litigated in other cases that Mr. Epstein is a resident of Florida"

"email of April 6 from Weinberg to McCawley (offering to let her know regarding acceptance of service on April 7)"

"introduce that evidence in a trial of this defamation claim between Plaintiff and Ms. Maxwell."

"Ms. Maxwell was the employee of Mr. Epstein --in the 1990s -- not the other way around."

"Plaintiff and Epstein fully resolved any claims against one another by way of a confidential settlement in 2009"

"In an email sent by Epstein to Ms. Maxwell on January 25, 2015, while the media maelstrom generated by Plaintiff’s false claims continued to foment, h"

"The lawyer who is currently representing Virginia (Brad Edwards)"

"The lawyer who is currently representing Virginia (Brad Edwards) was his partner. Need I say more."

"Plaintiff then also listed categories of witnesses such as all other then-minor girls... Ms. Maxwell anticipates filing in the near future a separate "

"Counsel for Ms. Maxwell only learned of the Rule 45 violation this past weekend after reviewing certificates of service provided by Plaintiff’s counse"

"McCawley Decl. in Support of Request to Exceed Ten Deposition Limit... Plaintiff ignored that request"

"Those disclosures listed 94 individual witnesses with knowledge regarding the facts of this case... just two, Jeffrey Epstein and Alan Dershowitz."

"purported victims of sexual abuse including a client of Mr. Edwards, who he has clearly known about for years."

"Mr. Alessi, however, did not appear on that date, believing that his deposition was for June 1, the same day that his wife had been subpoenaed to appe"

"VIRGINIA L. GIUFFRE, Plaintiff v. GHISLAINE MAXWELL, Defendant."

"counsel of record for Defendant Ghislaine Maxwell (“Maxwell”) in this action."

"Jeffrey S. Pagliuca (pro hac vice)... Attorneys for Ghislaine Maxwell"

"Plaintiff’s friend, confidante and former-Daily Mail journalist, Sharon Churcher"

"former-Daily Mail journalist, Sharon Churcher"

"Deposition of Rinaldo Rizzo on June 10, 2016"

"I am a member of the law firm Haddon, Morgan & Foreman, P.C."

"Sigrid S. McCawley... BOIES, SCHILLER & FLEXNER, LLP"

"Counsel for Plaintiff makes much of her efforts to serve witnesses Epstein, Marcincova and Kellen"

"correspondence produced in this case between Ms. Maxwell and Jeffrey Epstein from January 2015"

"Sigrid S. McCawley... BOIES, SCHILLER & FLEXNER, LLP"

"Bradley J. Edwards... FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L."

"he was the one who initiated contact with Brad Edwards after reading about the lawsuit"

"I was there to have sex with Jeffrey on the trip. After dinner I gave Jeffrey an erotic massage."