…law). The Second Circuit has explained that “the item filed must be relevant to the performance of the judicial function and useful in the judicial process in order for it to be designated a judicial document.” Amodeo I, 44 F…
…added). Detendant's participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and…
…You can answer. 5 of this lawsuit is, which would be, as 6 A. I just explained. 6 you've termed it, sexual trafficking of 7 A. I spent the entire time talking to 7 Ms. Roberts. 8 Virginia's…
…She has further explained that the recruitment of females through the offer of some legitimate position was the typical way in which Defendant and Epstein lured unsuspecting females to the house before converting the relationship into a sexual 7 one…
…F, 10:6-14; 43:15-44:4 As explained in in Wright & Miller, Federal Practice and Procedures, the use of a document during testimony to refresh recollections is limited: The law also places limits on how counsel and the…
…247, 270 (1981). As explained by the Reporters of the American Law Institute’s Restatement of Torts, when considering the size of punitive damages “[t]he wealth of the defendant is also relevant, since the purposes of exemplary damages are…
… She explained that she lived in Palm Beach 25 and didn't want butlers because they're too stuffy. Case 1:15-cv-07433-LAP Document 1199-18 Filed 01/27/21 Page 9 of 40 Page 9 1 And…
…would be accounted for by the previously-issued categorical entry. Regarding the same, it was explained to counsel for Defendant in a meet-an-confer call that the log takes into account any communications between Ms. Giuffre and any retained…
…435 F.3d 110, 119 (2d Cir. 2006). As explained above, this includes discovery motions. Only after the judicial determination is made may courts proceed to balance the weight of the presumption of access. Id. Respondent here makes the same…
…Defendant’s participation in massages with Epstein is a central part of this case. Ms. Giuffre has explained that during her first sexual encounter with Jeffrey Epstein, it was Defendant who provided instruction on how to do it and how…
…her and Ross Gow, and another email between her and Jeffrey Epstein. Defendant explained that they were not produced “following the Court’s in camera review in April” due to “clerical error.” See McCawley Dec. at Exhibit 3, August 16…
…confidence in the administration of justice.”). Indeed, the motion to intervene is devoid of any citations to precedent that allows an individual to exploit these bedrock legal principles solely for his personal benefit, rather than the public at large. Furthermore…
…your flight logs and journal. I told him you must remain a confidential source and the way he explained it was that all of the info you pass through me will not be used in court, only as a lead…
…emotional distress damages. 1. The information withheld is critically important As fully explained in the Motion to Compel Rule 26(a) disclosures, to date Plaintiff still has not provided an actual computation of the physical and emotional distress damages she …
…247, 270 (1981). As explained by the Reporters of the American Law Institute’s Restatement of Torts, when considering the size of punitive damages “[t]he wealth of the defendant is also relevant, since the purposes of exemplary damages are…
…and now other knowledgeable witnesses, have explained and testified that Defendant not only had knowledge of Epstein’s massages and sexual activity with others, but she actively facilitated the sexual massages through recruiting young females and underage girls for the…
…pursuant to Local Rule 33.3 prior to the last 30 days of discovery. See Menninger Decl. Ex. A. Her objection is unfounded, as defense counsel explained to her by letter of February 20, 2016. Id.at Ex. D. First…
…about Ms. Giuffre’s objections are largely moot, except for those few objections concerning documents that are actually being withheld, as explained in fuller detail below. 1. Ms. Giuffre’s Claims of Privilege are Appropriate Defendant asserts that Ms. Giuffre…
…Decl., Exhibit 9, Sur-Reply in Support Opposition to Motion to Compel. Cassell and Edwards also explained that communications with Ms. Giuffre were protected not only beginning in March 2014, but even earlier than that date when Ms. Giuffre understood…
…of Civil Procedure are premised on the belief that justice is best served when witnesses appear at trial to be examined and cross-examined by both parties. As this Court has explained, “There is a strong preference for live testimony…