…INTRODUCTION .......................................................................................................................... 1 I. PLAINTIFF CANNOT SATSIFY THE LEGAL REQUIREMENTS FOR USE OF CERTAIN DEPOSITIONS AT TRIAL .................................................................................. 1 A. Jeffrey Epst…
…ARGUMENT ..................................................................................................................................2 I. EPSTEIN AND, POTENTIALLY, ESPLIN ARE UNAVAILABLE WITNESSES.........2 A. Jeffrey Epstein is a Witness who is more than 100 miles from the place of …
…on remand. Setting aside issues of jurisdiction and prematurity, Ms. Maxwell’s counsel Jeffrey Pagliuca and I are unavailable to participate in-person in the conference (Laura Menninger is out of the country), although we could participate via telephone. Accordingly…
…Honor rescheduled the Conference for July 25, 2019 at 3:00 p.m. I am unavailable on July 25 due to travel and will likely not even have telephone access at that time. Rather than further delay the process toward…
…. . 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…
…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…
…and then Brunel’s attorney cancelled the rescheduled deposition date. Brunel’s counsel represented that Brunel was outside the country and thus unavailable. But later sworn deposition testimony revealed that Brunel was actually inside the country at this time – indeed…
…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…
…Evid. 32(a)(4)(B) (explaining that a witness cannot be considered to be “unavailable” where “it appears that the witness’s absence was procured by the party offering the deposition”). As the Court is also aware, Dershowitz filed a…
…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…
…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…
…I mean what if this woman has, you know, intimate knowledge of things about his body parts, for example, that will be unassailable proof that, in fact, she did have access to his body. The kind of thing that no…
…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…
…Menninger Declaration, Ex. A (Rizzo deposition transcript excerpts). Of course, Plaintiff's coW1Sel has engaged in their own last-minute "unavailability" for a deposition scheduled by Ms. Maxwell, as to Plaintiff's former fiance, a witness who is hostile, required…
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