Found 14 results for “unavailable” in 152ms

gov.uscourts.nysd.447706.91.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.91.0 3 pg

…Motion to Compel are at once novel (Plaintiff asserts, for example, a “public interest privilege” which is unavailable to individual, non-governmental litigants) and mundane (Plaintiff completely refused to answer interrogatories, even though they comply with the Federal and Local…

gov.uscourts.nysd.447706.1111.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1111.0 69 pg

…Moreover, the USVI also may be hindered absent intervention because this action involves testimony by and/or about Epstein, whereas his direct testimony is unavailable in the CICO action due to his death while in federal custody. Furthermore, the allegations…

gov.uscourts.nysd.447706.1331.27.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.27 11 pg

…. . is”3 Ms. Maxwell sent the earlier email to Mr. Barden originally and because he was unavailable, she forwarded it to Mr. Gow. Plaintiff’s reliance on this testimony is misplaced. Even if Mr. Gow’s speculation about how he…

gov.uscourts.nysd.447706.1219.43.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1219.43 12 pg

…of her long-time boyfriend and joint defense partner, Jeffrey Epstein. A blanket statement of “unavailability” is incredible – particularly without any description of the steps she has taken to make the emails available. Without taking any efforts to recover her …

gov.uscourts.nysd.447706.1161.0_1.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1161.0_1 17 pg

…Martindell involved a criminal investigation, which meant that the Government could take a number of significant steps that are unavailable in the USVI’s civil action here. 594 F.2d at 296 (noting that the Government “may institute or continue…

gov.uscourts.nysd.447706.1122.0_2.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1122.0_2 13 pg

…318 (1976)). Since Maxwell and Doe agree (as they must) that Epstein is unavailable to testify in the USVI’s CICO action and since his allegedly repeated invocations of the Fifth Amendment privilege in his deposition in this action would…

gov.uscourts.nysd.447706.49.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.49.0 12 pg

…Rule 26.4. Not surprisingly, Counsel for Ms. Maxwell was unavailable on the dates unilaterally selected by Plaintiff. Counsel for Ms. Maxwell attempted to have a professional conversation about an orderly discovery plan and, contemporaneously with that request, on February…

gov.uscourts.nysd.447706.872.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.872.0 76 pg

…Barden was not necessarily accessible at some point in time, so this had been sent to him orig inall y by Ms . Maxwell, and because he was unavailable , she forwarded it to me for immediate action. I therefore respond, "Okay…

gov.uscourts.nysd.447706.185.7.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.185.7 26 pg

…These files demonstrate the magnitude of Epstein's criminal conduct and the unlikelihood that Dershowitz was ignorant of his confidant and close friend's criminal behavior. Dershowitz complains that some of the documents are sealed or otherwise unavailable to him…

gov.uscourts.nysd.447706.1331.19.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1331.19 12 pg

…Mr. Barden was not necessarily accessible at some point in time, so this had been sent to him originally by Ms. Maxwell, and because he was unavailable, she forwarded it to me for immediate action. I therefore respond, “Okay, Ghislaine…

gov.uscourts.nysd.447706.218.0.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.218.0 25 pg

…684 N.Y.S.2d 443, 444 (1st Dep’t 1996) (“Notwithstanding [subpoenaing party’s] excuses offered to the contrary, no clear and specific showing has been made that the relevant material was unavailable elsewhere.”); Flynn, 235 15 Case…

gov.uscourts.nysd.447706.1320.28.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1320.28 32 pg

…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s former fiancé, a witness who is hostile, required…

gov.uscourts.nysd.447706.1256.12.pdf PDF

giuffre-maxwell gov.uscourts.nysd.447706.1256.12 32 pg

…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s former fiancé, a witness who is hostile, required…

1320-28.pdf PDF

giuffre-maxwell 1320-28 32 pg

…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff’s counsel has engaged in their own last-minute “unavailability” for a deposition scheduled by Ms. Maxwell, as to Plaintiff’s former fiancé, a witness who is hostile, required…

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