giuffre-maxwell
gov.uscourts.nysd.447706.1256.25
11 pg
…requested a substantive conferral call on this
issue. See Menninger Decl., Ex. B. In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1202.1_1
11 pg
…requested a substantive conferral call on this
issue. See Menninger Decl., Ex. B. In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.12
11 pg
…requested a substantive conferral call on this
issue. See Menninger Decl., Ex. B. In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the…
giuffre-maxwell
gov.uscourts.nysd.447706.276.0_1
35 pg
…25
SOUTHERN DISTRICT REPORTERS, P.C.
(212) 805-0300
Case 1:15-cv-07433-LAP Document 276 Filed 07/13/16 Page 2 of 35 2
G6ndgium
1 (Case called)
2 THE COURT: Extending discovery.
3 MS. McCAWLEY: Yes…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…there will be nothing for Dr. Esplin to “rebut” and
he will not be called as a witness in the defense case-in-chief. In light of the well settled rules
that a rebuttal expert is “intended solely to contradict…
giuffre-maxwell
gov.uscourts.nysd.447706.320.0
11 pg
…requested a substantive conferral call on this
issue. See Menninger Decl., Ex. B. In that correspondence, Defendant’s counsel gave specific
reasons for the objection to a number of the terms that were problematic in that they called for
the…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.1
18 pg
…reports produced in “response” to this Request bear date-stamps on them from
the issuing agency. All of the date-stamps post-date the March 21, 2016, phone call. Specifically,
they are from April 19, 2016 (e.g., GM_00802)…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…15-cv-07433-LAP Document 1335-7 Filed 01/09/24 Page 39 of 469
Highly Confidential
Page 38
1 HIGHLY CONFIDENTIAL AEO
2 Q. And what was -- what did you
3 tell her in your phone call?
4 A…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.35
5 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1327.24
6 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.13
5 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.1200.18
6 pg
… No, sir.
5 Q. So when there would be a message from one
6 of them while they were out of town, they would call
7 you, call you on the telephone?
8 A. I haven't spoken to Ghislaine…
giuffre-maxwell
gov.uscourts.nysd.447706.689.0
42 pg
…Circuit Case Law from LiButti v. United States Permits
Calling a Witness for Purposes of Obtaining Adverse Inferences.......................... 7
B. Federal Law Rather than New York Law Controls the Evidentiary Issue of
Whether Can Be Called as Witnesse…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.40
3 pg
…as a possible piece f,
her renowned Page Six column. It's called 'pure favor time' to Emily from the owner of the item, plus the press person wh
may or may not elect to pop it into print.
I…
giuffre-maxwell
gov.uscourts.nysd.447706.57.2
30 pg
…I shall not
distinguish between those two companies for the purposes of this judgment (because it is
not necessary to do so) and shall treat all relevant copyright and confidentiality rights as
being vested in what I will call "USP"…
giuffre-maxwell
gov.uscourts.nysd.447706.179.0
22 pg
…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…
giuffre-maxwell
gov.uscourts.nysd.447706.903.0
46 pg
…there -- and
18 I'm not accusing, I'm just afraid, because, you know, call it
19 spider sense or something -- what can happen is, we get to
20 trial and then someone says, oh, gee, he went on vacation…
giuffre-maxwell
gov.uscourts.nysd.447706.1219.28
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
212-556-1917
1
CONFIDENTIAL GM_01141
Case 1:15-cv-07433-LAP Document 1219…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.33
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
Jane Doe 2
1
CONFIDENTIAL GM_01141
Case 1:15…
giuffre-maxwell
gov.uscourts.nysd.447706.1328.27
3 pg
…November 12, 2015.
And call me if you have any questions.
Regards,
Barry Meier
--
The New York Times
620 Eighth Avenue
New York, NY 10018
212-556-1917
Jane Doe 2
1
CONFIDENTIAL GM_01141
…
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