giuffre-maxwell
gov.uscourts.nysd.447706.1295.11
19 pg
…subpoena to Ms. Ransome, and the questions posed to her in the February 17
deposition, it is important to understand how Ms. Ransome first came forward as a witness.
Based on her deposition testimony, sometime in October of 2016, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.30
19 pg
…subpoena to Ms. Ransome, and the questions posed to her in the February 17
deposition, it is important to understand how Ms. Ransome first came forward as a witness.
Based on her deposition testimony, sometime in October of 2016, Ms…
giuffre-maxwell
gov.uscourts.nysd.447706.1166.0_1
14 pg
…Maxwell’s rights to a fair trial by poisoning any venire and influencing witness testimony. For
reasons discussed below, the Court should decline to unseal the identified Sealed Items.
I. Ms. Maxwell’s July 22, 2016 deposition must remain sealed.
…
giuffre-maxwell
gov.uscourts.nysd.447706.1090.46
14 pg
…deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records .....................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.21
15 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.15
14 pg
…deposition, despite this Court’s order ........................................................................ 2
B. Plaintiff failed to produce emails from her iCloud and Hotmail accounts....................... 4
C. Plaintiff failed to address issue of her employment records .....................................…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.16_2
15 pg
…de osition testimon of 1) Ms. Giuffre;
and (4) Ms. Giuffre's p~an
o owmg witnesses for deposition: -
(8) a known victim of Jeffrey Epstein; (9) Mr.
Weisfield; (1…
giuffre-maxwell
gov.uscourts.nysd.447706.230.0
19 pg
…the deponent’s previous testimony. See, e.g, Vincent v.
Mortman, No. 04 Civ. 491, 2006 WL 726680, at *1–2 (D. Conn. Mar. 17, 2006) (allowing
plaintiff to reopen deposition when one witness' deposition contradicted defendants' deposition
and medical…
giuffre-maxwell
1320-21
15 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.24
16 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.17_1
16 pg
…remaining witness is - -
. His deposition is necessaiy for the following reason:
depositions like this - verifying Ms. Giuffre's account of being recrnited by Defendant for sex
with Epstein - that Defendant is hying avoid. However, multiple other witnesses have testimony
that…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.27
15 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
gov.uscourts.nysd.447706.1137.18_2
15 pg
…not something Ms. Giuffre can obtain through requests for production or through
intenogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recrniting and abuse, and those who…
giuffre-maxwell
1320-27
15 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
1320-24
16 pg
…not something Ms. Giuffre can obtain through requests for production or through
interrogatories. The only way of obtaining such evidence is from witness testimony by those
who were victimized, those who assisted Defendant in recruiting and abuse, and those who…
giuffre-maxwell
gov.uscourts.nysd.447706.1156.0
35 pg
…jury, unsealing the deposition material also risks compromising the integrity of witness
testimony because it provides an opportunity for a witness to change his or her story to conform
to the allegations made in the unsealed (and publicized) material.” Id…
giuffre-maxwell
gov.uscourts.nysd.447706.824.0_2
47 pg
…case.
15 So, your Honor, I believe, in my view, that there is
16 definitely a plethora of witness testimony we can utilize to,
17 first, authenticate under 901, which, as you know, that burden
18 is not extremely high…
giuffre-maxwell
gov.uscourts.nysd.447706.949.0
31 pg
…Court, it didn't have everything.
23 So after the summary judgment, your Honor will
24 remember there was other witness testimony that was presented
25 and put in the court record. There were designations for trial
SOUTHERN DISTRICT REPORTERS…
giuffre-maxwell
gov.uscourts.nysd.447706.994.0
14 pg
…Deposition Designations and Counter-Designations
Ms. Maxwell contends that trial deposition designations and counter-designations are not
judicial documents: In fact, pre-trial disclosures like this contain the direct witness testimony that
the parties were designating as public trial testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.7
21 pg
…testifying; and
(C) the use is allowed by Rule 32(a)(2) through (8).
To affirmatively offer evidence in her case in chief through deposition testimony under Rule
32(a)(4), the plaintiff must establish that the witness is unavailable…
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