giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…whether the party
requesting the deposition has had other opportunities to obtain the same information, and
whether the burden of a second deposition outweighs its potential benefit.’” Id. (quoting Ganci,
1
Case 1:15-cv-07433-LAP Document 1330…
giuffre-maxwell
gov.uscourts.nysd.447706.639.0
2 pg
…455 at 2.
In the interests of judicial economy, the parties believe it would be appropriate to
have the benefit of the Court's rulings on these other issues, review the designated
testimony in light of such rulings and then…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.12
10 pg
…Simply
put, she should not be allowed to benefit from her obvious failure to properly disclose Ms.
Ransome.
Ms. Ransome's Testimonv is ot Cumulative And Has Highly Relevant Evidence
Defendant also advances the remarkable argument that it is "unlikely…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.37
9 pg
…for his deliberate violation of the
settlement privilege will not be harsh enough to offset the benefit he received by feeding false
Case 1:15-cv-07433-LAP Document 1218-37 Filed 07/15/21 Page 3 of 9
…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.28
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1106.0_2
6 pg
…fundamentally unfair to
allow Giuffre to continue to press these allegations where she and her attorneys have had the full
benefit of discovery already conducted concerning these allegations which is in her possession and
which is being withheld Dershowitz and…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.1
42 pg
…Numerous depositions have already been taken by Ms. Giuffre without the
benefit of these documents. The window for authenticating the documents through depositions
7
Case 1:15-cv-07433-LAP Document 1332-1 Filed 01/08/24 Page 9…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…make a convoluted legal argument, not to actually seek
discoverable information. In light of this, the “burden or expense of the proposed discovery
outweighs its likely benefit, considering the needs of the case, the parties' resources, the
importance of the…
giuffre-maxwell
gov.uscourts.nysd.447706.1332.14
9 pg
…for two hour on each subject,
up to a total of four hours. The Defendant should not get a benefit from having twice improperly
withheld information, by collapsing the two hours needed to address each of these topics into an…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.41
31 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.1218.14
32 pg
…119 (2d Cir.
2006). The Second Circuit has explained that “documents that directly affect an adjudication
and play a significant role in determining litigants’ substantive rights receive the benefit of a
relatively strong presumption, while the public interest in other…
giuffre-maxwell
gov.uscourts.nysd.447706.1307.4
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.13_1
19 pg
…sanctions, “to ‘ensure that a party will not benefit from its own failure to
comply,’ to ‘obtain compliance with a particular order issued,’ and to ‘serve a general deterrent
4
Plaintiff lodged an objection to communications regarding “ongoing” investigations, but…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…followed in this case.
While requiring Mr. Epstein to invoke his Fifth Amendment privilege in front of the jury will
yield not even a marginal benefit to either party, there are substantial countervailing concerns that
weigh heavily against requiring Mr…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.10
28 pg
…be unreasonably
cumulative or duplicative, the requesting party had a prior opportunity in discovery to obtain the
information sought, or the burden or expense of additional depositions would outweigh any
likely benefit.” In re Weatherford Int'l Sec. Litig., No…
giuffre-maxwell
gov.uscourts.nysd.447706.1256.12
32 pg
…he had no role in issuance of the statement, he has
no benefit in the outcome of this litigation and he played no controlling role in its respect.
Similarly, there is not any evidence at all to support an adverse…
giuffre-maxwell
gov.uscourts.nysd.447706.1224.0
6 pg
…add any clarity to the process.
Approaching the Does in categories will have the added benefit of having only a few
responses and replies due in a particular round as the Objecting Does will be spread out amongst
the groups…
giuffre-maxwell
gov.uscourts.nysd.447706.164.0
29 pg
…actively participated in the litigation. Indeed, the testimony of Cassell makes clear that the
purpose of the litigation was for Plaintiff’s benefit, and that he wanted to do a “good job” for her.
Normally, an attorney cannot waive the…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.23
9 pg
…denying Ms. Giuffre the benefit of being able to use these e-
mails at multiple witness depositions. The only “untimeliness” claim that can be made here is against
1111
the Defendant.
-
The two emails in question are responsive to a…
giuffre-maxwell
gov.uscourts.nysd.447706.68.0
17 pg
…lawsuit is lost income. Her Rule 26 disclosure of the basis for calculating these damages was
extensive and is worth setting out here for the benefit of the Court:
Estimated lost income of $180,000 annually. Present value of $3…
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