During the Virginia Roberts Giuffre defamation lawsuit, Ghislaine Maxwell attempted to use Federal Rule of Civil Procedure 45 as a pressure tactic, asking the court to sanction Giuffre and her legal team over their handling of subpoenas. Maxwell argued that Giuffre improperly served or attempted to serve subpoenas on non-party witnesses without giving required advance notice, claiming this violated procedural rules and amounted to bad-faith discovery conduct. Maxwell framed the move as an abuse of the discovery process, alleging deadlines were ignored and that Giuffre was trying to extract testimony in ways that unfairly prejudiced Maxwell’s defense.
The court was ultimately unmoved by Maxwell’s effort, viewing it as part of a broader strategy to choke off discovery rather than a genuine procedural grievance. Judges made clear that technical disputes over subpoenas did not outweigh the public interest and relevance of the underlying evidence, especially given the serious nature of the allegations involved. Maxwell’s failed bid for Rule 45 sanctions instead reinforced a familiar pattern in the litigation: repeated attempts to delay, narrow, or derail discovery as damaging testimony and documents continued to edge closer to daylight.
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