…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…
…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…
…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 …
…a.m. EST. Case 1:15-cv-07433-LAP Document 87 Filed 04/07/16 Page 2 of 4 4. Counsel for Ms. Maxwell are both unavailable to appear in New York on April 13, 2016. 5. Mr. Pagliuca…
…time, so this had been sent to him 09:20:59 ·5· ·originally by Ms. Maxwell, and because he was 09:21:03 ·6· ·unavailable, she forwarded it to me for immediate action. 09:21:07 ·7· ·I therefore respond…
…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…
…on Ms. Maxwell’s counsel,” id. at 2, who has represented that her firm is unavailable to complete briefing until Defendant’s criminal trial is over. Under that case’s current schedule, trial will conclude sometime in January. At meet…
…. . 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…
… In 2009, did you direct your 6 lawyer, either directly or indirectly, to 7 tell Brad Edwards that you were unavailable 8 to attend a deposition? 9 MR. PAGLIUCA: Objection to the 10 form and foundation. And this is a…
…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…
…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…
…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…
…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…
…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…
…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…
…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…
…and some provid ers no longerex ist.A complete overview of what med icalrecord s are u navailable to M s.Giu ffre is below atA ppend ix A . Even if M s.Giu ffre had end less resou rces…
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