…you all want to spend every Thursday at noon in New York before the Court for no reason. We are in the process of the forensic examination of the devices. We expect to have that examination completed prior to Ms.…
…There is no privilege which attaches to a civil litigant’s prior statements to law enforcement and to the extent 8 Case 1:15-cv-07433-LAP Document 1090-46 Filed 07/30/20 Page 11 of 14 Case…
…iCloud, one on live.com, and one on hotmail.com during the relevant time periods. Plaintiff’s counsel confesses that prior to being confronted on the issue, they never reviewed the emails in the accounts for relevant information. Menninger Decl.…
…There is no privilege which attaches to a civil litigant’s prior statements to law enforcement and to the extent 8 Case 1:15-cv-07433-LAP Document 1325-15 Filed 01/04/24 Page 11 of 14 any…
…Notes of Advisory Committee on Rules—1993 Amendment. Here, had Plaintiff conferred with Ms. Maxwell prior to filing her motions to compel, several issues could have been resolved without Court intervention. While this list is by no means exhaustive, Ms…
…has already acknowledged, Dershowitz should not be forced to “litigate this action with one arm tied behind his back.” (Dkt. No. 144). For the foregoing reasons and the reasons explained in his prior filings on this subject, Dershowitz respectfully requests…
…available at prior deposition and had or could obtain the information through other discovery devices). Here, Plaintiff’s sole justification for an extraordinary third deposition are two irrelevant documents that are cumulative of information previously produced, covering topics on which…
…always maintained, that all non-privileged relevant and responsive documents in her possession, custody and control had already been searched for and produced prior to the excessive and redundant briefing on these issues, resulting in no additional production. Plaintiff’s…
…Therefore, both of these documents are highly relevant. Whatever Defendant argues 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…
…Civil Procedure. She admits she simply had not, prior to designating testimony, even attempted to serve these witnesses or obtain their attendance at trial. She has now obtained an agreement to accept service by Mr. Epstein’s counsel, mooting any…
…affidavit. Most importantly the decision was issued prior to Plaintiff’s testimony in the Dershowitz case where she voluntarily testified about her attorney communication in a manner affirmatively waiving privilege (as noted by the magistrate judge overseeing the deposition). The…
…you all want to spend every Thursday at noon in New York before the Court for no reason. We are in the process of the forensic examination of the devices. We expect to have that examination completed prior to Ms…
…be able to cross her with and ask related questions. Therefore, both of these 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…
…very next page, when discussing the information gleaned from those police reports that Mr. Pagliuca had prior to the conferral call, Defendant claims the information from the police reports is “irrelevant,” stating: “The records requested are irrelevant. Plaintiff has asserted…
…Filed 01/03/24 Page 9 of 32 June 18, 2016). “Good cause” and diligence were not shown when a party raised the prospect of a deposition nine days prior to the discovery deadline. Carlson v. Geneva City School Dist.…
…face. Plaintiff apparently fled the scene with her boyfriend prior to the arrival of the police. The report documents that Plaintiff had a fiancé in or around June 2001, when she claims she was a “sex slave” to Jeffrey Epstein…
…instruction not to answer was given. These questions had been asked in the first deposition, could have been asked in greater detail in the first deposition, and were answered in both depositions prior to the instruction not to answer being…
…was about to be discovered. In addition to the examples discussed in the opening brief, most recently, the day prior to the deposition of Detective Joseph Recarey (noticed by Plaintiff), over 650 pages of previously undisclosed documents relating to his…
…relating to the settlement of the Dershowitz Case, Plaintiff and her attorneys again affirmatively cite to Plaintiff’s communications with them, their investigation of her statements, and their assessment of her credibility. The references include the time frame prior to…
…requirement that prior notice “must be given has important underpinnings of fairness and efficiency.” Cootes Drive LLC v. Internet Law Library, Inc., No. 01– CV–9877, 2002 WL 424647, *2 (S.D.N.Y. Mar. 19, 2002). Plaintiff fails to …
Comments