Epstein Secrets

documents relating to communications with you and Ross Gow from 2005 — present. DOCUMENT REQUEST NO. 18

ntiff, by and through her undersigned counsel, hereby propounds Plaintiff's First Request for Production of Documents pursuant to Rules 26 and 34 of the Federal Rules of Civil Procedure to the Defendant Ghislaine Maxwell. The responses are due at the offices of Boies, Schiller & Flexner LLP, 401 East Las Olas Boulevard, S

GLE County Buyer Information JOHNSON. ELIZABETH ROSS EPSTEIN. JEFFREY E 457 MADISON AVE NEW YORK, NY

76 2015 U.S. Dist. LEXIS 87203, * already served their Rule 26(a)(1) disclosures (DE 266 at 13), and although this Court has repeatedly held that the Federal Rules of Civil Procedure "govern the general course of this proceeding," the Government maintains that the rule governing initial disclosures in civil litigation

47 Thru P-003751 File folder entitled "Adrian Ross" containing subpoena and correspondence regardi

e victims were not properly notified about event during that investigation. 59. RFP No. 25 requests all initial productions that are required under the Federal Rules of Civil Procedure. This is a protective request to ensure that, should it be determined that the Civil Rules apply, they then receive all materials to whic

42 Filed 01/13/23 Page 49 of 163 Kellen, Adriana Ross, and Nadia Marcinkova) with immunity from federal

ther Class Members. 313. This action has been brought and may properly be maintained as a class action against Deutsche Bank pursuant to Rule 23 of the Federal Rules of Civil Procedure because there is a well-defined community of interest in the litigation and the proposed Class is readily and easily ascertainable from D