…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…
…is not required to. provide prices or values for securities or other Property in your Account(s). You acknowledge that prices or values for the Property may be unavailable or. it available. unreliable When the Bank includes values for the…
…matter for January 10, 2011. 2. The undersigned counsel is unavailable that day due to specially set trials in the case of Penelope Lankheim v Florida Atlantic University, beginning January 10th through January 12th, 2011 before Judge Rosenberg and the…
…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 …
…that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-issue. Given…
…clients. However, Mr. Nurik indicated to me that Mr. Rothstein would be unavailable for a deposition at any time in the near future. I have noticed Mr. Rothstein's deposition on April 15, 2010 (solely on the default issue), recognizing…
…This date was unilaterally set by Edwards. Edwards was repeatedly informed by counsel for Epstein that counsel was unavailable on that date and that it was outside of the discovery cutoff. However, to date he has refused to either cancel…
…is reasonably available to represent you before the Discipline Hearing Officer; 3. The right to call witnesses (or present written statements of unavailable witnesses) and to present documentary evidence in your behalf, provided institutional safety would not be jeopardized; 4…
…that Mr. Epstein should be required to appear because defendant Maxwell has objected to the use of Mr. Epstein's deposition testimony, claiming that he is not an unavailable witness. Response at 3. This is simply a non-issue. Given…
…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…
…> . However, I am unavailable tomorrow (Monday) because of prior commitments until approximately 7:45 PM. =ext, you should know that I'm not an employee of CFI nor do I have any authority to speak on behalf of CFI…
…2d 48, 50 (8th Cir. 1973) (stating that no evidentiary hearing is necessary where the files and records of the case demonstrate that relief is unavailable or where the motion is based on a question of law). Stated differently, a…
…said she needs contact with someone from your office within 48 hours (by Friday) to at least make a note that the process has begun. If ou are unavailable, I can call her back and she will reset the date…
…unable to do so. 13. If OCC determines that the exercise settlement value for any cash-settled foreign currency option is unavailable for purposes of calculating the cash settle- ment amount. OCC has the authority to suspend the settlement obligations…
…despite the fact that he was advised by Plaintiffs counsel that the Plaintiff was unavailable during this time and that there was no basis for the taking of a second deposition when the Plaintiff had already been deposed in 2010…
…make the residual hearsay clause inapplicable. I. THE RESIDUAL HEARSAY CLAUSE CANNOT BE USED TO CURE UNAVAILABLE DECLARANT Plaintiff's first fundamental error is her failure of proof that the identified declarants are unavailable to be called as witnesses. Fed…
…the arguments against their industry. They tout their product as a healthy alternative to sugary drinks and say that it's a safer option for those who live in areas where clean tap water is unavailable. And their message seems…
…despite the fact that he was advised by Plaintiffs counsel that the Plaintiff was unavailable during this time and that there was no basis for the taking of a second deposition when the Plaintiff had already been deposed in 2010…
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