giuffre-maxwell
gov.uscourts.nysd.447706.1046.0
3 pg
…Dkt. 279: Motion for Adverse Inference Instruction,
Dkt. 345: Motion to Compel Production of Documents Subject to Improper Objection, and
Dkt. 659: Second Motion to Compel.
To illustrate the utility of this approach, at the March 31, 2020, conference, the…
giuffre-maxwell
gov.uscourts.nysd.447706.1021.0
18 pg
…ideas that we have come up
17 with -- we have submitted the letter to you, obviously, which
18 poses an approach dealing with the non-parties. One other
19 piece of that, if it would be beneficial to the Court…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.37
11 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.12
35 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.25
10 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.132.1
31 pg
…Honor,
4 of just making a very short little cheat sheet of the
5 outstanding issues, if I may approach.
6 THE COURT: Yes. It will be interesting to see if
7 yours is the same as the one we…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.30
40 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.22
40 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1201.22_1
12 pg
…As she is trying to explain, and
11 I'm asking questions because I'm as feared as
12 she is at this point. We hear people
13 approach and she just shuts up.
14 Q. What happens next?
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.31.0_1_1
22 pg
…7 Thank you.
8 MS. McCAWLEY: Good morning, your Honor. May I
9 approach with a bench book?
10 THE COURT: Sure.
11 MS. McCAWLEY: Thank you.
12 THE COURT: I think in duplicate. Do you have another
13 copy…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.3
223 pg
…four hours in my mind is
13 not a hard and fast four hours based upon how we
14 proceed in this deposition. So I'll take that
15 into consideration as we approach the four hours.
16 A. Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…they're specifically talking
20 about here.
21 THE COURT: Thank you very much. I will reserve
22 decision.
23 The motion to quash the Epstein --
24 MR. POE: May I approach the podium, your Honor?
25 THE COURT: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1326.1
45 pg
…with
During a sworn taped statement, stated she met
Jeffrey Epstein through Haley Robson. Robson would approach females
who wished to work for him. ••■■~ stated she was asked to.work for
him but declined. •■■■9explained that work means give…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.13
45 pg
…with
During a sworn taped statement, stated she met
Jeffrey Epstein through Haley Robson. Robson would approach females
who wished to work for him. ••■■~ stated she was asked to.work for
him but declined. •■■■9explained that work means give…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.18
23 pg
…7 Thank you .
8 MS. McCAWLEY : Good morning, your Honor. May I
9 approach with a bench book?
10 THE COURT : Sure .
11 MS. MCCAWLEY : Thank you.
12 THE COURT: I think in duplicate . Do you have another
13 copy…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…Epstein often settles lawsuits out of court. She has
22 testified that she read that statement and decided to approach
23 the reporter to try to sell her story. She did that just a
24 couple weeks before she called…
giuffre-maxwell
gov.uscourts.nysd.447706.1199.18_1
40 pg
…8 Q. And how did you meet her?
9 A. She approached me while I was on campus at
10 Palm Beach Atlantic College.
11 Q. And what happened when she approached you?
12 A. She asked me if I…
giuffre-maxwell
gov.uscourts.nysd.447706.1257.17
12 pg
…As she is trying to explain, and
11 I'm asking questions because I'm as feared as
12 she is at this point. We hear people
13 approach and she just shuts up.
14 Q. What happens next?
15 …
giuffre-maxwell
gov.uscourts.nysd.447706.1328.23
22 pg
…To
leave the discovery until later would be burdensome on the jury – meaning that a common
approach is to allow financial discovery to proceed pre-trial and then to later bifurcate the trial
itself into liability and punitive damages phases…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.15_2
41 pg
…DE 282 at 2. But Jane Doe No. 3 was simply following the same approach that Jane
Doe No. 2 had taken earlier, by filing a motion to join rather than a proposed amendment to pleadings.
6
Case 1…
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