…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. …
… potential witness in criminal Note: The deponent is not on the CI-6 trial and deposition testimony Non-Party notification list CI-7 …
…deposition testimony as well as her responses to Requests for Admission, Ms. Giuffre should be entitled to use this post-litigation communication, where Gow asks Defendant, “Please advise how you wish to respond,” to cross Defendant on her prior deposition…
…without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 2. As used in this Protective Order, …
… from this 398-5 8.24.16 Rule 23.1; potential witness in criminal trial CI-5; CI-6; Doe to and deposition testimony potential CI-7 remain evidence. …
…without limitation, documents produced, answers to interrogatories, responses to requests for admission, deposition testimony, and other information disclosed pursuant to the disclosure or discovery duties created by the Federal Rules of Civil Procedure. 2. As used in this Protective Order, …
… potential witness in criminal Note: The deponent is not on the CI-6 trial and deposition testimony Non-Party notification list CI-7 …
… My deposition testimony includes the following information that Mr. Edwards and I relied upon in believing the truth of Giuffre’s allegations: a. The Palm Beach Police Department put together an 87-page report based on witness interviews and other…
…Transcript of January 19, 2021 at 9 (“Finally, excerpts of any deposition testimony for nonparty Does in the Court of Appeals that has already been unsealed may be unsealed here also with redactions, if any, ordered by the Court of…
… My deposition testimony includes the following information that Mr. Edwards and I relied upon in believing the truth of Giuffre’s allegations: a. The Palm Beach Police Department put together an 87-page report based on witness interviews and other…
…Maxwell and Non-Party deposition C1-1 testimony, Non-Party identifying C1-2 231 6.20.16 information, and argument of C1-3 counsel violative of Local C1-4 …
…Argument................................5 Ms. Giuffre’s Deposition in the Defamation Case...........................................................................7 The Settlement of the Defamation Case..........................................................................................7 LEGAL ST…
…a witness at any trial.” (DE 311 at 17 n.7). The necessary “participation” of Jane Doe 3 and Jane Doe 4 in this case can be satisfied by offering their properly supported—and relevant, admissible, and non-cumulative—testimony…
…position on J un e 16 , 2016. The Subpoena also commands Churcher to br i ng with h er to t he deposition several broad categories of documents : l . All Documents containing communications with Virginia Roberts. 2. All communications with…
…Case ........................................................................................................................................... 2 The Dershowitz case ........................................................................................................................ 4 The Florida Court Rejects a Waiver of…
…Argument................................5 Ms. Giuffre’s Deposition in the Defamation Case...........................................................................7 The Settlement of the Defamation Case..........................................................................................7 LEGAL ST…
…and 12, 2016, unilaterally and without conferral noticed a number of depositions in Florida and New York to occur shortly after the notices were served. It would have been obvious to any experienced trial lawyer that it was unlikely, given…
…protocol, last October, Dershowitz also sought, in Dershowitz, the “immediate[]” production of two non-public sets of documents, including Giuffre’s partially sealed deposition taken in Maxwell. Dershowitz, DE 71. This Court denied that request as well, on November 5…
…Maxwell and Non-Party deposition C1-1 testimony, Non-Party identifying C1-2 231 6.20.16 information, and argument of C1-3 counsel violative of Local C1-4 …
…party has vested in the non-party witness in regard to the key facts and general subject matter of the litigation will likely inform the trial court whether the assertion of the privilege should be viewed as akin to testimony …