…NON-PRIVILEGED QUESTIONS IN HER FIRST DEPOSITION ......... 10 III. PLAINTIFF MADE MATERIAL CHANGES TO HER DEPOSITION THAT COMPLETELY CONTRADICT HER SWORN TESTIMONY ...................................... 13 CERTIFICATE OF SERVICE ........................................................................................…
…Despite these obstacles, non-party Ransome complied by producing over 235 pages of highly relevant documents which include photographic evidence and e-mail communications during the mid-2000s that directly contradict Defendant’s deposition testimony. For example, Defendant swore under…
…document because the underlying motions remain undecided, that ruling would contradict the Second Circuit’s holding in Brown that whether a district court actually relies on a document has no bearing on whether it is a judicial document. See Brown…
…To the contrary, she states that there was ‘no proof’ that he was a ‘pedo’– which directly contradicts such a suggestion in itself – but only that [Ms. Giuffre] ‘probably met him when he was hanging out with [Jeffrey Epstein]’. Reply…
…critical.” See Burke, 700 F.2d at 77-78.6 To the extent that Maxwell seeks Churcher’s communications with and about Ms. Roberts to find evidence that might contradict or otherwise impeach testimony from Ms. Roberts, it is well…
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