…about her prior deposition, she cannot claim that she was questioned about these two emails. Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery Concerning These Emails is Not Duplicative, and it is Highly Relevant…
…documents are highly relevant. Whatever Defendant argues about her prior deposition, she cannot claim that she was questioned about Ms. Giuffre deserves the opportunity to ask Defendant about them. II. ARGUMENT A. Discovery Concerning is Not Duplicative, and it is…
…Trafficking Organization Is Also Admissible Under Rule 404(b) to Show Motive and Plan. .........................................................................................................................7 C. Evidence of Defendant’s Involvement in Epstein’s Sex Trafficking …
…Parties.........................................6 II. THE COURT SHOULD USE ITS DISCRETION TO PRECLUDE INTRODUCTION OF TESTIMONY FROM A WITNESS MS. GIUFFRE HAS NOT HAD THE OPPORTUNITY TO CROSS EXAMINE. ............................................................................8 A. Allowing…
…under seal in 1 Case 1:15-cv-07433-LAP Document 1068 Filed 06/24/20 Page 6 of 24 their entirety until every Non-Party listed therein receives notice and has an opportunity to request excerpts and object…
…Notably, Defendant withheld these documents until that second deposition was completed, thus depriving Ms. Giuffre the opportunity to ask questions on those emails. Finally, Ms. Giuffre has been asking for April dates for this deposition since March. After repeated requests…
…In addition to or instead of this sanction, the court, on motion and after giving an opportunity to be hear (A) may order payment of the reasonable expenses, including attorney's fees, caused by the failure; (B) may inform the…
…information at this time. If necessary, plaintiff will have an opportunity to obtain discovery on the defendant's financial circumstances as part of any post-trial discovery. Since the trial in this matter is a bench trial, no jury will…
…In addition to or instead of this sanction, the court, on motion and after giving an opportunity to be hear (A) may order payment of the reasonable expenses, including attorney's fees, caused by the failure; (B) may inform the…
…information at this time. If necessary, plaintiff will have an opportunity to obtain discovery on the defendant's financial circumstances as part of any post-trial discovery. Since the trial in this matter is a bench trial, no jury will…
…In addition to or instead of this sanction, the court, on motion and after giving an opportunity to be hear (A) may order payment of the reasonable expenses, including attorney's fees, caused by the failure; (B) may inform the…
…In addition to or instead of this sanction, the court, on motion and after giving an opportunity to be hear (A) may order payment of the reasonable expenses, including attorney's fees, caused by the failure; (B) may inform the…
…severe and extensive sexual abuse. See Ex. A, ¶¶ 40-114. Epstein and his associates lured these girls and young women to his island with promises of modeling and other career opportunities. Id., ¶ 49. Once they arrived, though, they were sexually…
…not have had a working understanding of the process in the first place.1 Ms. Giuffre argues that “[a]llowing Non-Parties multiple opportunities to object to unsealing would set a precedent that would exponentially delay this process.” (Dkt. no…