…Miami Herald claims to practice. Indeed none of the descriptions of alleged sexual activities or unsupported claims of sex with nonparties would be relevant to the Herald’s claimed investigation of a “cross-border sex-trafficking ring,” Mot. to Unseal…
…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. …
…21 and to witnesses who may be able to provide evidence of a wider, cross-border sex-trafficking ring. In connection with its ongoing investigation, the Miami Herald has sought to access public court filings that will shed light on…
…from the deposition testimony of a deceased individual, who Ms. Maxwell never had the opportunity to cross- examine, and who (contemporaneous with his deposition) was convicted of a felony and sent to prison for stealing, and then trying to sell…
…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..................................................…
…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..................................................…
…1987) (where attorney took stand, privilege waived for information necessary to cross-examine attorney). To be sure, parts of Barden’s Declaration appear to have been cleverly written in an attempt obscure the fact that he is revealing attorney-client…
…Giuffre, Plaintiff, Case No: 15-cv-07433-RWS v. Ghislaine Maxwell, Defendant. ____________________________/ PLAINTIFF’S OBJECTIONS TO DEFENDANT’S DEPOSITION DESIGNATIONS AND PLAINTIFF’S CROSS DESIGNATIONS Plaintiff Virginia Giuffre, hereby subm…
…action pertaining to JE Every story in the press innuendo and comment has been taken from civ depositions against JE, which were settled many years ago. None of the depositions were ever subject to cross examination, not one. any I …
…JURY..................................................................................................................... 4 II. SUMMARY TESTIMONY IN THE FORM OF COONAN’S “EXPERT” OPINION IS IMPERMISSABLE AND VIOLATES MS. MAXWELL’S RIGHT TO CONFRONT AND CROSS EXAMINE WITNESSES ..................................................…
… B Judgment delivered 22 July 2008. Specific disclosure – Litigation privilege – Cross-examination – When court could go behind affidavit of documents – Third party sought specific disclosure of documents – Litigation privilege claimed – Ma…
…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…
…Dershowitz Brittany N. Henderson, Esq. 6 Meridith Schultz, Esquire 7 - - - 8 I N D E X 9 10 WITNESS DIRECT CROSS REDIRECT RECROSS 11 Virginia Roberts Giuffre By Ms. Borja …
…the commencement of this litigation (as shown by the document at issue) is - evidence to the contrary. Ms. Giuffre should be able to cross her with that email and ask related questions. Therefore, both of these documents are highly relevant…
…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…
…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 …
…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…
…order to prevent delay or interruption of the trial, have sufficient witnesses.at all times during the trial and shall perpetuate before trial the direct and cross-examination testimony of any essential witness. 4. The parties shall submit to the…
…Dershowitz Brittany N. Henderson, Esq. 6 Meridith Schultz, Esquire 7 - - - 8 I N D E X 9 10 WITNESS DIRECT CROSS REDIRECT RECROSS 11 Virginia Roberts Giuffre By Ms. Borja 5 12 …
…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 …