giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…In order to investigate, as we would be obligated to do and
3 entitled to do, your Honor, we would be forced to engage in
4 cross-border discovery. A simple Rule 45 subpoena would not
5 suffice, your Honor. …
giuffre-maxwell
gov.uscourts.nysd.447706.988.1
5 pg
…02-17-2017 Defendant’s Objections to Plaintiff's Cross Designations................................................ 8
03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9
03-28-2017 Notice of filing Typographical Errors..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.988.0_2
6 pg
…02-17-2017 Defendant’s Objections to Plaintiff's Cross Designations................................................ 8
03-28-2017 Response to Defendant’s Objections to Plaintiff's Designations...................................... 9
03-28-2017 Notice of filing Typographical Errors..................................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.9
12 pg
…Page 5 of 12
Page 4
1 I N D E X
2 WITNESS: PAGE:
3 JEFFREY EDWARD EPSTEIN
4 DIRECT EXAMINATION 8
BY MR. CASSELL:
5
CRO…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.7
11 pg
…Ms. McCawley, to
18 allow Mr. Scarola a couple questions on
19 examination on cross and then my ruling is going
20 to be as follows: You can go ahead and ask
21 whatever questions you want, Mr. Scarola, at…
giuffre-maxwell
gov.uscourts.nysd.447706.303.0
13 pg
…obligation to respond to each interrogatory
including its related subparts, separately and fully.
A submission by that party's counsel which cross-references pleadings and
exhibits is simply not an answer to that interrogatory by that party. It must be
…
giuffre-maxwell
gov.uscourts.nysd.447706.64.0
14 pg
…1996) ............................................. 7
Fausto v. Credigy Svcs. Corp., 251 F.R.D. 427 (N.D.Ca. 2008) ........................................ 7
Hartman v. Am. Red Cross, No. 09–1302, 2010 WL 1882002 (C.D.Ill. May 11, 2010) .... 7
Lane v. Smith, Jr., 84…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.25_1
13 pg
…obligation to respond to each interrogatory
including its related subparts, separately and fully.
A submission by that party's counsel which cross-references pleadings and
exhibits is simply not an answer to that interrogatory by that party. It must be
…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.6
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1338.1
134 pg
…383 South University Street BY MR. CASSELL:
Salt Lake City, Utah 84112 5
5 Phone: 801.585.5202 CROSS-EXAMINATION 275
E-mail: [email protected] 6 BY MR. PAGLIUCA:
…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.15
27 pg
…Uete1..UVC1 VVCI C U 1
giuffre-maxwell
gov.uscourts.nysd.447706.1090.18
11 pg
…Thus, the factors to be considered
have simply been moved to a new number with cross reference.
4
Case 1:15-cv-07433-LAP Document 1090-18 Filed 07/30/20 Page 6 of 11
Weighing these factors, there…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.16
17 pg
…2900217, at *1
(S.D.N.Y. Oct. 4, 2007) (Sweet, J.) (denying motion and cross motion based on failure to confer,
noting “[m]ere correspondence, absent exigent circumstances not present here, does not satisfy
the requirement”); Myers v. Andzel…
giuffre-maxwell
gov.uscourts.nysd.447706.831.0_2
59 pg
…witness in this case is
9 highly relevant. If she came forward because she has a money
10 motive to be a witness in this case, that is motive and that is
11 cross-examination material, your Honor. She testified…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…he
is not, then there is no rebuttal witness, and none to cross examine.
II. WAS NOT PROPERLY “REFRESHED” AND THE READING OF
THE HEARSAY POLICE REPORT IS INADMISSABLE
The use of the deposition testimony of , and the reading or…
giuffre-maxwell
gov.uscourts.nysd.447706.563.0
10 pg
…no need to resort to such recorded testimony. Ms.
Giuffre will appear at trial at testify during her case-in-chief and, of course, be cross-examined
by defense counsel. In addition, Ms. Giuffre will be available to be a…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…Thus, the factors to be considered
have simply been moved to a new number with cross reference.
4
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 6 of 11
Weighing these factors, there…
giuffre-maxwell
1320-20
11 pg
…Thus, the factors to be considered
have simply been moved to a new number with cross reference.
4
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 6 of 11
Weighing these factors, there…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…benefit.” Thus, the factors to be considered
have simply been moved to a new number with cross reference.
4
Case 1:15-cv-07433-LAP Document 189 Filed 06/06/16 Page 6 of 11
Weighing these factors, there…