…through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") and his Counsel from making any mention or use of the below-listed items/matters/witness testimony at trial'. In support thereof…
…13, 2007 Republished in De Novo Vol. 11, No. 6 September 2008 TESTIFYING - Expert Witness Testimony APPOINTMENTS - Hearing testimony for the District Court, Jefferson County, Colorado …
…then there is no rebuttal witness, and none to cross examine. II. MS. WAS NOT PROPERLY "REFRESHED" AND THE READING OF THE HEARSAY POLICE REPORT IS INADMISSABLE The use of the deposition testimony o and the reading or summary of…
…2015)(no abuse of EFTA00585748 discretion in finding witness unavailable where attorney had represented to court that client would assert Fifth Amendment privilege). Third, plaintiff argues that Mr. Epstein "contaminated" his <…
…counsel for the witness with a 3 hour deposition to accomplish the same end. 5 EFTA00097400 Case 1:15-cv-07433-RWS Document 189 Filed …
…Cir. 2015)(no abuse of discretion in finding witness unavailable where attorney had represented to court that client would assert Fifth Amendment privilege). Third, plaintiff argues that Mr. Epstein "contaminated" his deposition testimony through his initial assertion of the privilege…
…s Answers and Affirmative Defenses in all civil 43. cases against him All Complaints in which Jeffrey Epstein was a plaintiff or 44. defendant …
…Cir. 2015)(no abuse of discretion in finding witness unavailable where attorney had represented to court that client would assert Fifth Amendment privilege). Third, plaintiff argues that Mr. Epstein "contaminated" his deposition testimony through his initial assertion of the privilege…
…please? 6 with her lack of education could have written that 7 Do you swear or affirm that the testimony 7 deposition. 8 you are about to give will be the truth, the 8 I sought the advice of friends…
…party, witness, or person providing discovery in this case, IT IS ORDERED: I. This Protective Order shall apply to all documents, materials, and information, including without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and…
…telephone number and cellular telephone number, and ident please state the substance of each witness's testimony. EFTA01076814 VERIFICATION By: …
…identify her counsel. Also, please state the substance of each witness's testimony. 10 EFTA01076855 VERIFICATION …
…the defendants advised Judge Koeltl that they are seeking relief from the Protective Order so that they can use the deposition testimony and documents that Jane Doe produced as a third party witness in the Giuffre Matter ("Jane Doe Evidence")…
…discovery; rather, it is the Plaintiff who is seeking to engage in a one-sided and premature fishing expedition. As we previously advised the Court, the Plaintiff gave deposition testimony and egio documents in a matter captioned v. Maxwell, No…
…Overbroad, unduly burdensome, violation of constitutional right of privacy; and harassing; e. May allow to fabricate and tailor her testimony before her deposition occurs; and f. It is an Improper Medical Examination pursuant to Fla. R…
…documentation produced in discovery. All deposition testimony and discovery responses by Epstein submitted in this action. All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. All submissions by Epstein in connection with the Rothstein deposition. All Settlement Agreements between…
…AND DEPOSITION TESTIMONY I have testified approximately 35-40 times in the Commonwealth of Virginia and the States of Texas and Maryland on issues related to forensic urine drug testing, forensic chemistry, and controlled substance analysis. I have provided testimony…
…Edwards on behalf of victims of Epstein's criminal molestations. All attachments to Edwards' Motion for Summary Judgment. 150. All time records and hourly billing documentation produced in disco …
…on the part of [the witness] to cooperate with the government" is proper subject of Rule 17(c) subpoena). Similarly, documents containing prior statements of a witness that are inconsistent with that witness's testimony at trial can be admissible…
…Bradley Edwards' Motion to Determine Entitlement to Adverse Inference and Precluding Epstein From Offering Evidence at Trial Page 5 of 13 SEC would not be able to depose him or to use his testimony in any deposition of Alan Hirshberg…