…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…
…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…
…sir. 9 BY MR. CRITTON: 9 Q. If he had offered to do that would you 10 Q. And when we were here, I think it was 10 have read what he wrote down to determine whether 11 last week…
…and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. • stated Epstein penetrated her vagina with his…
…proof to the Court that it is. She has offered no explanation as to why her five (or six) attorneys are unable to prepare a privilege log as to their communications with her, or any other documents withheld as privileged…
…and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. • stated Epstein penetrated her vagina with his…
…proof to the Court that it is. She has offered no explanation as to why her five (or six) attorneys are unable to prepare a privilege log as to their communications with her, or any other documents withheld as privileged…
…to why she could access one email account from Epstein’s private server, but not her other account from Epstein’s private server. No details are offered. Accordingly, Defendant fails to meet her burden under Rule 26(b)(2)(B…
…they offered to reopen discovery 7 to allow her to be deposed and also accept service of the 8 subpoena. 9 We are here today to talk about her refusal to answer 10 certain questions during her deposition that occurred…
…none of which are satisfactorily met in the circumstances here. (1) the statement has equivalent circumstantial guarantees of trustworthiness; (2) it is offered as evidence of a material fact; 6 Case 1:15-cv-07433-LAP Document 1331-16…
…public. At the very least, the Court should conduct an in camera review of any joint defense agreements that exist to determine their relevance to both the defamation claim and the multiple affirmative defenses offered by Defendant. See Steuben Foods…
…Ms. Giuffre respectfully requests that Court exclude from the case the excerpts from the deposition of Ms. Giuffre that have been offered by the Defendant. Dated: January 27, 2017 Respectfully Submitted, BOIES, SCHILLER & FLEXNER LLP …
…and fondled her breast with his hands as she provided the massage. stated on one occasion, he offered extra monies to have vaginal intercourse. She stated this all occurred on the massage table. • stated Epstein penetrated her vagina with his…
…March 8, 2016, counsel for Mr. Epstein informed plaintiff’s counsel that Mr. Epstein would invoke his Fifth Amendment privilege in connection with any deposition and offered to provide an affidavit. Poe Decl., Exhibit 2. Nearly a month later, on…
…signed and the documents have been produced; and 2) there is no prejudice because they have offered to permit the re-deposition of Plaintiff on newly revealed medical providers and belatedly produced documents. The law does not permit a Plaintiff…
…law. A ma t erial dispute of fact exists as t o t h e "admitted trut h" or the "real i ty" in this case . The details and significance of the f a cts offered are highly contested, and…
…public. At the very least, the Court should conduct an in camera review of any joint defense agreements that exist to determine their relevance to both the defamation claim and the multiple affirmative defenses offered by Defendant. See Steuben Foods…
…adverse inferences against defendants in criminal cases, it ‘does not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them.’” 107 F.3d at 121 (quoting Baxter v. Palmigiana…