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…
DataSet-9
EFTA00808421
5 pg
…due to Edwards'
bifurcation of his Counterclaim and ensuing appeal, there is sufficient time before Edwards'
Counterclaim is reset for trial for Edwards to take the witness's deposition. Epstein will not
object to opening discovery for that limited purpose…
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
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…
DataSet-9
EFTA01113462
3 pg
…of depositions, each intends to
offer as testimony in his, her or its case in chief. No later than 10 DAYS PRIOR TO TRIALresch
opposing party shall serve his, her, or its counter (or "fairness") designations to portions of
depositions…
DataSet-9
EFTA00809163
6 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
EFTA00597471
6 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
EFTA00724077
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…
giuffre-maxwell
gov.uscourts.nysd.447706.203.0
15 pg
…TRIAL TESTIMONY.
All of the people Ms. Giuffre seeks to depose have discoverable and important
information regarding the elements of Ms. Giuffre’s claims.
Defendant has unilaterally scheduled - without consulting counsel for Ms. Giuffre - at least two
of these depositions…
DataSet-9
EFTA00808609
11 pg
…in Opposition to Epstein's Renewed Motion for Leave to Disclose Expert Witness
flight logs); ¶ 36 (alleged improper depositions of pilots); ¶ 38 (alleged improper scheduling of
depositions of well-known figures).
6. Thus, any purported expert testimony concerning Edwards's…
DataSet-9
EFTA00788395
2 pg
…the defendants advised Judge Koeltl that they are seeking relief from the Protective
Order so that they can use the deposition testimony and documents that Jane Doe produced as a
third party witness in the Giuffre Matter ("Jane Doe Evidence")…
giuffre-maxwell
gov.uscourts.nysd.447706.1330.17
12 pg
…her alleged emotional distress, her material contradictory changes to testimony, and
any statements published and attributed to her by the media she admits are false. Ms. Maxwell
did not request to reopen the deposition to seek cumulative, duplicative and/or…
giuffre-maxwell
gov.uscourts.nysd.447706.455.0
4 pg
…witness depositions in at least 3 states including California, Florida, and Colorado.
Discovery motions are pending before this Court and the United States District Court for the
Southern District of Florida, including, but not limited to, motions to compel deposition…
DataSet-9
EFTA00728661
5 pg
…intends to offer as
testimony in that party's case-in-diet No later than 10 DAYS BEFORE CALENDAR CALL each opposing
party shall serve counter (or "fairness") designations to portions of depositions designated, together with
objections to the depositions…
DataSet-9
EFTA00728666
5 pg
…party intends to offer as
testimony in that patty's case-in-chief. No later than10 DAYS BEFORE CALENDAR CALL, each opposing
party shall serve counter (or "fairness") designations to portions of depositions designated, together with
objections to the depositions…
giuffre-maxwell
gov.uscourts.nysd.447706.1325.7
30 pg
…recently, a witness testified that Defendant would call him and ask him to bring over young girls
that she would provide to Epstein. See McCawley Decl. at Exhibit 9, ROUGH Deposition
Transcript of Tony Figueroa at 162:8-19. It…
giuffre-maxwell
gov.uscourts.nysd.447706.1198.12_3
30 pg
…not to Ms. Giuffre, who long ago authorized the
release of all records. The existence of a record that a witness failed to produce prior to a
deposition is not a discovery violation from Ms. Giuffre.
III. MS. GIUFFRE HAS…