Epstein Secrets

06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to C

Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 1 of 15 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK X Plaintiff. v. GHISLAINE MAXWELL, Defendant. X 15-cv-07433-RWS DEFENDANT'S REPLY IN SUPPORT OF MOTION TO COMPEL NON-PRIVILEGED DOCUMENTS Laura A. Menninger Jeffrey S.

ent With Her Own Attorneys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as foll

ys 10 CERTIFICATE OF SERVICE 13 EFTA00618133 Case 1:15-cv-07433-RWS Document 191 Filed 06/06/16 Page 3 of 15 Defendant Ghislaine Maxwell ("Ms. Maxwell") files this Reply In Support of her Motion to Compel Non-Privileged Documents contained on Plaintiff's Privilege Log, stating as follows: INTRODUC

o v. Stanley Black & Decker Inc., No. CV 13-3963 JFB SIL, 2015 WL 136011, at *2 (E.D.N.Y. Jan. 9, 2015) (citing Baki v. B.F. Diamond Constr. Co., 71 F.R.D. 179, 181-82 (D.Md. 1976)); Eisai Co. v. Teva Phann. USA, Inc., 247 F.R.D. 440, 441-42 (D.N.J. 2007). Ms. Maxwell has not sought discovery of "facts kno

407 A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: Q: Do you, is she neither would you agree that neither Jane Doe nor L.M. have testified to any, that they had any connection whatsoever with Ghisl

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

ctions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iowa State University of Science and Technology, 152 F.R.D. 179 (S.D. Iowa 1993) ("The style adopted by [deponent's counsel]...will not be tolerated by this court. Merely because depositions do not take place in

-23. A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: 6 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00585399 Q: Do you, is she neither would you agree that neither Jane D

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

ctions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iowa State University of Science and Technology, 152 F.R.D. 179 (S.D. Iowa 1993) ("The style adopted by [deponent's counsel]...will not be tolerated by this court. Merely because depositions do not take place in