…A. Jeffrey Epstein and Ronald Rizzo Are Not Unavailable Plaintiff cannot claim that Jeffery Epstein and Ronald Rizzo are “unavailable witnesses” whose testimony can be presented by deposition at trial under Rule 34 of the Federal Rules of Civil Procedure…
…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 …
…effort to hide relevant information and prevent the fair examination of Plaintiff on her claims. Due to these multiple and repeated discovery violations, key information and documents were unavailable to Ms. Maxwell prior to Plaintiff’s depositions on May 3…
…A party may establish relevance by “‘adduc[ing] sufficient evidence from which a reasonable trier of fact could infer that ‘the destroyed [or unavailable] evidence would have been of the nature alleged by the party affected by its destruction.’” Id…
…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…
…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…
…is 2 necessary in the event that the deposition goes forward, but 3 that kind of prejudice is the prejudice created by this lawsuit 4 and that's unavoidable, so I don't think that there is any 5 prejudice…