…Sanctions ........................................................................................................... 133 C. Preclusion of Plaintiff’s Claims for Emotional Distress and Physical and Psychological Damages is Warranted .....................................................................................…
…Sanctions ........................................................................................................... 133 C. Preclusion of Plaintiff’s Claims for Emotional Distress and Physical and Psychological Damages is Warranted .....................................................................................…
…to work 20 after Mar-a-Lago? 21 A I think she went with Mrs. Maxwell. 22 Q But do you know where, physically? 23 A Physically, Sky and I dropped her off one 24 day at Mrs. Maxwell's…
…Epstein to physically appear to assert his Fifth Amendment privilege in front of the jury. While it may be true that there is no blanket prohibition in all civil cases against calling a witness who will assert his Fifth Amendment…
…2010 Deposition Transcript of Nadia Marcinkova, attached hereto as Exhibit 28. C. Computation of damages: 1. Physical, psychological and psychiatric injuries and resulting medical expenses – in an amount of approximately $ 102,200 present value. a. Computation Analysis: …
…trial is simply wrong. Plaintiff offers a single criminal case, United States v. Amuso, which addressed the admissibility of evidence of physical flight from the jurisdiction as proof of consciousness of guilt. 21 F.3d 1251, 1258 (2d Cir. 1994)…
…any other person. Indeed, though the Manuscript describes sexual encounters Ms. Giuffre allegedly had with a different member of the Harvard faculty—whom she identifies by name and physical characteristics—it levels no such accusation against Professor Dershowitz. Dershowitz Decl. …
…Tr. at 199. Her stepmother’s phone, e-mail address and physical address – despite the fact that non-party Ms. Ransome already gave testimony at her lengthy deposition that she does not have her stepmother’s contact information. See…
…including the depositions of the infant plaintiffs, reveal intimate details about the sexual and physical abuse these children have been subjected to during their lives.”). Does 55 and 56 have not raised any such countervailing interest here. Even assuming that…
…192. x During the ten (10) year statute of limitations period, Epstein used threats to ensure Jane Doe 43 complied with his physical demands including forcing her to stop eating so she could meet his demands. Jane Doe 43 Dep…
…Tr. at 199. Her stepmother’s phone, e-mail address and physical address – despite the fact that non-party Ms. Ransome already gave testimony at her lengthy deposition that she does not have her stepmother’s contact information. See…
…for the subpoenaing party. 2. This Request calls for the production of all responsive Documents in your possession, custody or control without regard to the physical location of such documents. 3. If any Document was in your possession or control…
…not a plaintiff. She is 11 not going to be revealing any names today of an 12 individual who is going to harm her physically, 13 period. If we have to go to Judge Lynch on that 14 we will…
…Tr. at 199. ! Her stepmother’s phone, e-mail address and physical address – despite the fact that non-party Ms. Ransome already gave testimony at her lengthy deposition that she does not have her stepmother’s contact information. See Pottinger
…follows: 5 Case 1:15-cv-07433-LAP Document 68 Filed 03/23/16 Page 9 of 17 1. Physical, psychological and psychiatric injuries and resulting medical expenses – in an amount of approximately $ 102,200 present value. a…
…Of course, such specialized testimony is useful to a jury, because it comes from a medical doctor with expertise on the nature of physical injuries. In contrast, Taylor does not offer opinions that fall within the competence of an accountant…
…bias) 4. Whether Alan Dershowitz contacted anyone on her behalf (communications with others by counsel not privileged) 5. Her stepmother’s phone number and email address and physical address (she claims that they spoke with Ms. Maxwell and Mr. Epstein…
…On February 12, 2016, Ms. Maxwell served Interrogatories on Plaintiff for the identities and locations of any Health Care Provider from whom she has “received any treatment for any physical, mental or emotional condition, including addiction to alcohol, prescription or…
…With fact discovery to close in four days, no lesser sanction than preclusion of Plaintiff’s claims for emotional distress damages and physical and psychological damages claims will be effective to remedy this willful non-compliance. C. Plaintiff Misrepresents Witness…
…other evidentiary materials.” Id. In her November 2015 disclosures, Plaintiff first stated that she suffered: (1) Physical, psychological and psychiatric injures and resulting medical expenses—precise amount yet to be computed, but not less than $100,000.00; (2) Past…
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