Found 33 results for “normal routine standard” in 404ms

gov.uscourts.nysd.447706.1256.16.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.16 30 pg

…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…

gov.uscourts.nysd.447706.1325.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.7 30 pg

…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…

gov.uscourts.nysd.447706.1256.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.19 30 pg

…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…

gov.uscourts.nysd.447706.1325.14.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1325.14 30 pg

…communications with counsel) and her Motion to Compel for Improper Objections. Even then, Defendant’s counsel refused to even take the routine step of looking at Defendant’s email and other electronic documents to find responsive documents, but produced, instead…

gov.uscourts.nysd.447706.1327.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.7 9 pg

…did -- do you recall what when 21 you observed the other females giving massages, do 22 you recall what they would dress like? Did they 23 wear scrubs or did they typically wear normal 24 clothes? 25 A. Normal clothes . …

gov.uscourts.nysd.447706.1078.1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1078.1 8 pg

…unwarranted and prejudicial pretrial publicity by the Government, its agents, and lawyers for alleged witnesses. Legal Standard More than fifty years ago, warning of the danger of pretrial publicity to fair trials, the Supreme Court directed trial judges to take…

gov.uscourts.nysd.447706.1296.2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1296.2 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

gov.uscourts.nysd.447706.1320.10.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.10 28 pg

…the witnesses to appear via a trial subpoena. Accordingly, Ms. Giuffre seeks leave to take more than the standard ten depositions in this case. At this time, she seeks leave to take seven additional depositions, as articulated below.2 2…

gov.uscourts.nysd.447706.1201.1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1201.1_1 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

gov.uscourts.nysd.447706.1320.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.12 179 pg

…21 A. Palatial. When you walk up, it looks like 22 a normal door to a townhouse, and when you walk 23 in -- I thought there were four floors. I heard 24 there were seven floors. I didn't see…

gov.uscourts.nysd.447706.1327.5.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1327.5 17 pg

…defense counsel once again ranged far beyond the normal parameters of objections and gave instructions directly in contravention of this Court’s Order directing Defendant to answer exactly the type of questions posed to her. In light of Defendant’s…

gov.uscourts.nysd.447706.831.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.831.0_2 59 pg

…around Spain by some unknown people. She 19 saw them a few times. She would go out on her normal route, 20 and she saw the same people. She thought they were following 21 her, so she got rid of…

gov.uscourts.nysd.447706.1137.1_1_1_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1137.1_1_1_1 10 pg

…In this case, defense counsel ranged far beyond the normal parameters of objections and sought to decide for himself what issues were relevant. That was improper and the Court should order a resumption of the Defendant's deposition so that…

gov.uscourts.nysd.447706.1320.6.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.6 10 pg

…such inquiries are crucial to impeaching the Defendant at trial. During her deposition, Defendant attempted to characterize her work for Epstein as nothing more than a normal job handling hiring for the various mansions. See McCawley Decl. at Exhibit 1…

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