… intervenor Dershowitz; and intervenors Julie Brown and Miami Herald (collectively “Miami Herald”). So they present more or less similar arguments. We request leave to address their three separate briefs in a single reply brief. We submit this will be more…
…subjects covered by the emails. Moreover, despite having access to other email communications that are similar in nature and substance to the two email communications Plaintiff now claims are “key” documents, Plaintiff elected to not examine Ms. Maxwell on those …
…similar to other conclusory assertions this Court has rejected in the past. Maxwell also asserts that the Court should stay the unsealing process because “the Second Circuit’s ruling regarding the appeal was issued late in the day” on Monday…
…expert witness she must carry the affirmative burden on proving: 1) Plaintiff “attempt[ed] to secure the voluntary [trial] attendance of a witness who lives beyond the subpoena power of the court” and 2) that no similar expert is available…
…and now Defendant’s Motion to Compel Disclosure of Criminal Investigation, or Alternatively, Motion to Stay [DE 101], all requesting a stay of her deposition or similar relief. Defendant’s deposition has been scheduled for March 2, 2016, March 25…
…group (the AON group), used the final form draft CAA as a starting point for the drafting of a similar document which they put forward in their bid to devise and operate a scheme for Powerhouse. In doing so they…
… and that paragraph 2(d) be similarly revised to provide 30 days (rather than 14 days) for non-parties to submit an objection to unsealing/unredacting and 14 days (rather than 7 days) for non-parties to file a reply…
…produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical conditions), and Plaintiff’s Introduction and Conclusions should be stricken as impertinent and scandalous. Similarly, Plaintiff devotes pages to inaccurate accounts of Ms…
…provisions that only allows parties to bring challenges to the Protective Order.” November 2, 2016 Sealed Opinion (emphasis added). Similarly here, the Epstein Defendants only have possession of these documents because Epstein was a witness in this matter bound by…
…is a misstatement of fact compounded by Plaintiff’s intentional omission of the previous page of deposition testimony which exposes the falsehood. Similarly, Detective Joe Recarey never “testified that Defendant procured underage girls for Epstein.” (Reply at 4) To the…
…is a misstatement of fact compounded by Plaintiff’s intentional omission of the previous page of deposition testimony which exposes the falsehood. Similarly, Detective Joe Recarey never “testified that Defendant procured underage girls for Epstein.” (Reply at 4) To the…
…produce medical records (indeed none of the witnesses discussed know a single thing about Plaintiff’s medical conditions), and Plaintiff’s Introduction and Conclusions should be stricken as impertinent and scandalous. Similarly, Plaintiff devotes pages to inaccurate accounts of Ms…
…Giuffre contends, including but not limited to, awards in other similar matters, that the 16 Case 1:15-cv-07433-LAP Document 69-2 Filed 03/23/16 Page 18 of 21 amount is not less than $30,000,000…
…21 address her claimed $30 million emotional distress from a 22 defamation statement that was a denial of her allegations 23 versus any emotional distress or emotional conditions she 24 already had before any such statement was made. 25 Similarly…
…she testified that Regardless, Plaintiff is looking in vain for more testimony of exactly the same character, precisely the type of testimony the presumptive limit is intended to prevent. Similarly, the expected deposition testimony of former Palm Beach Detective Joe…
…JK-15-029, 828 F.3d 1083, 1088 (9th Cir. 2016). An overbroad subpoena is “equally indefensible as a search warrant would be if couched in similar terms.” Id. (quoting Hale, 201 U.S. at 77). A subpoena is overbroad…
…Epstein’s sexual abuse, the Department accumulated overwhelming evidence placing underage girls at Epstein’s residence who gave statements that they were being sexually abused, the accounts bearing chillingly similar details. As he did to Ms. Giuffre, Dershowitz called those…
…personal financial information, claimed to be related only to issue of punitive damages, as premature before dispositive motions). In circumstances such as these, the procedure followed in a similarly contentious case by this Court, Guccione v. Flynt, may be the…
…counsel formerly representing the Non-Party alerted the Court that they no longer represented the individual and Plaintiff found new addresses for service. Counsel assumes that the return rates for the other 96 Non-Parties served by Plaintiff are similar…
…20 foundation. 21 THE WITNESS: Some did, some did not. 22 BY MS. SCHULTZ: 23 Q. Okay. Among the girls who did not know 24 one another, were their accounts of what happened at 25 Jeffrey Epstein's house similar?
Comments