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
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…
DataSet-9
EFTA00582821
24 pg
…2017 is consistent with his Complaint against Edwards, his sworn testimony at
deposition regarding the facts known to him at the time he filed his Complaint and each
amendment thereto, which is also supported by all documentary evidence also provided…
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…
DataSet-9
EFTA00097359
17 pg
…some of the same witness testimony that it will use to prove the Mann Act
Counts. Resp. 141-42. That argument is unavailing. First, the government admits that only "in
one instance" does a charged deposition question relate to a…
DataSet-9
EFTA00097312
17 pg
…some of the same witness testimony that it will use to prove the Mann Act
Counts. Resp. 141-42. That argument is unavailing. First, the government admits that only "in
one instance" does a charged deposition question relate to a…
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…
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…
DataSet-9
EFTA00589510
10 pg
…Cir. 2015)(no abuse of
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 deposition testimony through
his initial assertion of the privilege…
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…