…Because Ms. Giuffre has shown the importance of reopening Defendant’s deposition on these several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these…
…BACKGROUND .............................................................................................. 1 III. DISCUSSION ...................................................................................................................... 2 A. Ms. Giuffre’s FBI 302 is Offered to Prove That She Reported Her Alleg…
…Because Ms. Giuffre has shown the importance of reopening Defendant’s deposition on these several important documents, because Defendant has not offered any substantial countervailing consideration, the Court should allow Ms. Giuffre to question Defendant in a deposition about these…
…That conferral was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
…Ms. Giuffre has correctly explained why Taylor should not be allowed to opine on The remaining opinions offered by Taylor would not be relevant or helpful to the jury, which is why Taylor should be precluded from testifying at all…
…which “‘honor’ killings are a real risk,” and “instead concluding [that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20. (internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
…That conferral was held on May 9 and May 10. Mr. Edwards offered, for example, to consider whether a verified representation by Plaintiff all of the statements that the media “got wrong” would suffice instead of a re-opened deposition…
…of Dr. Phillip W. Esplin (hereinafter “Esplin”). PRELIMINARY STATEMENT Ms. Giuffre has moved to exclude three opinions offered by Defendant’s expert Esplin, specifically any opinions regarding See McCawley Dec. at Exhibit 1, Defendant has already c…
…2) holding that the transcript of Giuffre’s deposition in a separate action, offered by a third-party in support of a motion to intervene in this case, was entitled to no more than a “barely cognizable” presumption of public…
…VI. TAYLOR SHOULD BE PRECLUDED FROM OFFERING ANY OPINIONS REGARDING ............................................ 9 TAYLOR SHOULD BE PRECLUDED FROM OFFERING ANY OPINIONS REGARDING .....................…
…Limine 4) ....... 9 5. Prince Andrew and Buckingham Palace’s denials of Plaintiff’s claims are not offered for the truth of the matter asserted (Motion in Limine 5).............................................. 11 6. Evidence Regarding Plaintiff’s Sexual History and Reputation is…
…Raddatz, 447 U.S. 667, 677 (1980) (due process guarantees an accused the right to challenge the admissibility of evidence offered against her). If the government’s conduct was unlawful and unconstitutional, as Ms. Maxwell contends it was, Judge Nathan…
…which “‘honor’ killings are a real risk,” and “instead concluding [that] she . . . offered no more than generalized concerns of adverse publicity.” Doe 107 Br. at 2, 20. (internal quotation marks omitted). We assume the parties’ familiarity with the underlying facts…
…2) holding that the transcript of Giuffre’s deposition in a separate action, offered by a third-party in support of a motion to intervene in this case, was entitled to no more than a “barely cognizable” presumption of public…
…3, 2019). There, the proposed intervenors sought “materials (1) offered into evidence but excluded by the Court at trial, (2) used to refresh a witness’s recollection, or (3) discussed on the record but never moved into evidence.” Id. at…
…Counsel for (4) Jeffrey Epstein, offered to accept service on or about April 11 but Plaintiff ignored that offer for more than six weeks. Plaintiff only began on June 12 any attempt to schedule that deposition in the Virgin Islands…
…offered to have sex with him in exchange for not telling her parents she had failed to go to school that day. Both Plaintiff and her 17-year old boyfriend verified they had had sexual intercourse in the days before…
…could not do so without notice and an opportunity to be heard—only to find out that the testimony she offered with the district court’s blessing was the primary evidence against her in a criminal case and the basis…
…Maxwell has offered to provide responses to specific questions in writing (despite the fact that discovery has closed) which is the least burdensome and less expensive means of obtaining responses to the limited inquiry proposed regarding the two documents. ARGUMENT…
…reasonable reliance 13 might apply. First, Professor Dershowitz has offered 14 unequivocally -- and subject only to rights he would enjoy 15 anyway, to get the Court to issue a further order changing the 16 status quo, but -- to join the…