…but you can see the defendant, Ms. Maxwell, 11 and Mr. Epstein talking about fabricating evidence by producing 12 a non-existent witness who will cover up for Ms. Maxwell. 13 MR. PAGLIUCA: Your Honor, I object to this. 14…
…and denying us the ability, because of the redactions, to 5 cross-examine her about what she actually said because the 6 redactions cover up the content for the most part. 7 Your Honor, prior consistent statements, I think our …
…and denying us the ability, because of the redactions, to 5 cross-examine her about what she actually said because the 6 redactions cover up the content for the most part. 7 Your Honor, prior consistent statements, I think our …
…receipt of payments from Epstein, and documents showing her attempts to cover up her wrongful sexual abuse of minors are relevant. There are already materials implicating Defendant’s post-2008 involvement with Epstein and the related cover-up. For example…
…or otherwise restrain witnesses from giving evidence, because the defendants are using privilege to cover up wrong-doing (a sort of "clean hands" point), the claimants Case 1:15-cv-07433-RWS Document 57-2 Filed 03/14/16…
…15 Here's my concern, your Honor, I guess: If there's a 16 witness that shows up in court, I think it's prejudicial to the 17 defendant if we're using initials or things like that, because 18 …
…the Court’s suggestion due to scheduling conflicts until January of next year, and asserted 1 The Non-Party Objectors’ documents cover approximately 200 to 250 docket entries, a list of which the Parties can exchange in advance of briefing…
…fact, seeking only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual activity.” Plaintiff’s Motion to Compel Deposition Questions…
…is that 5 that is simply an incorrect characterization of the 6 relationship. 7 Since 2011, and continuing up, frankly, through the 8 present day, Ms. Churcher has continued to cover this story as 9 a reporter, has published stories…
…fact, seeking only to response Plaintiff on one subject: “Defendant should be ordered to sit for a follow-up deposition and directed to answer questions regarding her knowledge of alleged “adult” sexual activity.” Plaintiff’s Motion to Compel Deposition Questions…
…to confer with Defendant to secure her agreement to be deposed on this new information, Defendant refused to sit for a follow up deposition (despite the fact that Ms. Giuffre agreed to sit for her deposition under these same circumstance)…
…Shield Law applies, Maxwell has met the three elements to overcome the qualified privilege for non- confidential materials. Neither argument holds up to scrutiny. I. MAXWELL HAS FAILED TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY A. …
…statement from house employee Juan Alessi in which he revealed that girls would come over to give “massages” and he observed Ms. Maxwell going upstairs in the direction of the bedroom quarters. See Decl. of Sigrid McCawley at Exhibit 7…
…Shield Law applies, Maxwell has met the three elements to overcome the qualified privilege for non- confidential materials. Neither argument holds up to scrutiny. I. MAXWELL HAS FAILED TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY A. …
…Shield Law applies, Maxwell has met the three elements to overcome the qualified privilege for non- confidential materials. Neither argument holds up to scrutiny. I. MAXWELL HAS FAILED TO SHOW THAT CHURCHER WAS NOT ENGAGED IN PROTECTED NEWSGATHERING ACTIVITY A. …
…any way. If Defendant calls Esplin as a witness at trial, Ms. Giuffre would then have no need to rely upon his deposition testimony, as she would simply cover the same terrain via live questions before the jury. Should, however…
…s motion clearly establishes. Presumably the reason Defendant has raised privilege with Barden is that documents exist that are responsive to Ms. Giuffre’s request for production. Numerous discovery requests in this case cover Barden documents. More obviously, Ms. Giuffre…
…295 (2d Cir. 1979). Unless protective orders are “fully and fairly enforceable,” persons relying upon such orders will be inhibited from providing essential testimony and information in civil litigation, “thus 2 undermining a procedural system that has been successfully developed…
…Corp. 222 F.R.D. 74 (S.D.N.Y. 2003).................................................................................................13 In re Grand Jury Subpoena Duces Tecum Served Upon Shargel, 742 F.2d 61 (2d Cir. 1984) ........................................................................................................10 I…
… This 21 case is about the plaintiff's false allegations. 22 THE COURT: Yes. I think I picked up on that. 23 MR. PAGLIUCA: These are the lawyers that wrote the 24 false allegations. 25 THE COURT: I think I…
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