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.447706.230.0
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
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.447706.949.0
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…
DataSet-9
EFTA00589467
8 pg
…id. at 14-15, that
deposition testimony of the witness was available in lieu of personal appearance before the July
to assert the Fifth Amendment privilege. The Court, stressing that the determination must be
made on a case-by-case…
DataSet-10
EFTA01358948
1 pg
…11909, **
To evidence intentional deceit, the plaintiffs present: expert witness testimony describing
the characteristics of the pages as inherently deceptive; a 2010 congressional report
condemning Trilegiant's post-confirmation offer and refund mitigation practices as
deceptive and exploitative in 2010…
DataSet-9
EFTA00585747
8 pg
…2015)(no abuse of
EFTA00585748
discretion in finding witness unavailable where attorney had represented to court that client
would assert Fifth Amendment privilege).
Third, plaintiff argues that Mr. Epstein "contaminated" his <…
DataSet-9
EFTA00805442
16 pg
…actual or nominal
damages, Dr. Jansen must be stricken as a witness and his testimony precluded.
CONCLUSION
Edwards has no actual damages. That is why he wants to try a per se defamation action.
However, the litigation privilege is absolute…
giuffre-maxwell
gov.uscourts.nysd.447706.1122.0_2
13 pg
…after he was deposed as a fact witness in this action,
but before the USVI filed its action and could obtain his testimony therein. Maxwell and Doe
both argue that Epstein’s deposition is of no relevance to the USVI…
giuffre-maxwell
gov.uscourts.nysd.447706.993.0
28 pg
…had to review the proposed trial testimony designations for each witness
to determine how he would rule on objections to the testimony that would be presented to the jury.
As noted above, the trial deposition designations and counter-designations were…
DataSet-9
EFTA01107653
19 pg
…intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO
CALENDAR CALL each opposing party shall serve his, her, or its counter (or "fairness")
designations to portions of depositions designated…
giuffre-maxwell
gov.uscourts.nysd.447706.1149.0
18 pg
…Inadmissible in the Criminal
Action Risks Tainting and Prejudicing the Jury Pool
The deposition testimony and witness names and information that may be revealed in this
unsealing may or may not be presented (or even admissible) in the Criminal Action…
DataSet-9
EFTA00808590
19 pg
…the adverse nature of the testimony. Other factors which may
enter into the trial court's exercise of discretion are: (i) the objecting party's ability
to cure the prejudice or, ... [its] independent knowledge of the existence of the
witness…
DataSet-9
EFTA00066350
14 pg
…Research re Grand Jury Transcript (file folder)
Original proposed Ind (file folder) — includes original indictment
Research re Overt Acts and Witness Testimony (green file folder)
Extradition (green file folder)
Corporate Liability Research (green file folder)
Research re Knowledge of Age…
DataSet-9
EFTA00194822
18 pg
…of Prosecution Research
Research re Grand Jury Transcript (file folder)
18 USC 2255 (file folder)
Research re Grand Jury Transcript (file folder)
Original proposed Ind (file folder) — includes original indictment
Research re Overt Acts and Witness Testimony (green file folder)
…
DataSet-9
EFTA01126529
5 pg
…depositions, each intends to
offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO TRIAL, each
opposing party shall serve his, her, or its counter (or "fairness") designations to portions of
depositions…
DataSet-9
EFTA00614368
4 pg
…intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO
CALENDAR CALL, each opposing party shall serve his, her, or its counter (or "fairness")
designations to portions of depositions designated…
DataSet-9
EFTA00597394
6 pg
…each intends to
offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO TRIAL each
opposing party shall serve his, her, or its counter (or "fairness") designations to portions of
depositions designated…
DataSet-9
EFTA01123157
4 pg
…intends to offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO
CALENDAR CALL, each opposing party shall serve his, her, or its counter (or "fairness")
designations to portions of depositions designated…