…documents were protected by a non-existent “investigative privilege.” When Ms. Maxwell demonstrated that the “investigative privilege” does not exist, Plaintiff threw up the inapplicable “public interest” privilege, the assertion of which was overruled by your Honor on April 21…
… however, Plaintiff wants the opportunity to demonstrate to the jury just how disingenuous Defendant’s argument is on this topic and in the interest of fairness believes she should have that opportunity. WHEREFORE, Plaintiff moves this Honorable Court to Order…
… It's true, is it not, Mr. Epstein, you have 20 no economic interest in this litigation? 21 MR. CASSELL: Form and foundation. 22 Calls for a legal conclusion. 23 THE WITNESS: Fifth. 24 BY MR. PAGLIUCA: 25 Q. And…
…THE WITNESS: Fifth. 21 and foundation. 21 BY MR. CASSELL: 22 THE WITNESS: Fifth. 22 Q. You currently have a common interest 23 BY MR. CASSELL: 23 agreement with Maxwell, true? 24 Q. And whenever I us…
…THE WITNESS: Fifth. 21 and foundation. 21 BY MR. CASSELL: 22 THE WITNESS: Fifth. 22 Q. You currently have a common interest 23 BY MR. CASSELL: 23 agreement with Maxwell, true? 24 Q. And whenever I us…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…by, nor of counsel for any of the parties or 16 attorneys herein, nor otherwise interested in the 17 result of the within action. 18 In witness whereof, I have affixed my 19 signature this 31st day of May, 2016…
…did she 8 give you any other directions about what you should 9 write? 10 A She was interested in two things, really. 11 How Epstein got away with so many counts of child 12 trafficking for sex and how…
…need 13 to be left alone. 14 Q. Okay. I understand. 15 Have you had any communication with anyone 16 who represents the interests of Ghislaine Maxwell in 17 the last -- 18 A. Absolutely not. 19 Q. Okay. 20 A…
…did she 8 give you any other directions about what you should 9 write? 10 A She was interested in two things, really. 11 How Epstein got away with so many counts of child 12 trafficking for sex and how…
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