DataSet-9
EFTA00585420
25 pg
…through his undersigned
counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley
Edwards ("Edwards") and his Counsel from making any mention or use of the below-listed
items/matters/witness testimony at trial'. In support thereof…
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.447706.1137.16_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
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
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
EFTA00073158
10 pg
…13, 2007
Republished in De Novo
Vol. 11, No. 6 September 2008
TESTIFYING - Expert Witness Testimony
APPOINTMENTS -
Hearing testimony for the District Court, Jefferson County, Colorado
…
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.447706.1137.18_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…
DataSet-9
EFTA00595612
21 pg
…then there is no rebuttal witness, and none to cross examine.
II. MS. WAS NOT PROPERLY "REFRESHED" AND THE READING OF
THE HEARSAY POLICE REPORT IS INADMISSABLE
The use of the deposition testimony o and the reading or summary of…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.16
10 pg
…he
is not, then there is no rebuttal witness, and none to cross examine.
II. WAS NOT PROPERLY “REFRESHED” AND THE READING OF
THE HEARSAY POLICE REPORT IS INADMISSABLE
The use of the deposition testimony of , and the reading or…
giuffre-maxwell
gov.uscourts.nysd.447706.1331.36
10 pg
…limited use of Mr. Epstein’s deposition testimony would serve these purposes
equally well, as the jury would be left in no doubt as to why the plaintiff had not called Mr. Epstein
as a witness.
Finally, defendant Maxwell has…
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
EFTA00097394
12 pg
…counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
EFTA00097400
Case 1:15-cv-07433-RWS Document 189 Filed …
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.447706.1090.18
11 pg
…counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
Case 1:15-cv-07433-LAP Document 1090-18 Filed 07/30/20 Page 7 of 11
Putting aside the admissibility of this testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.1320.20
11 pg
…counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 7 of 11
Putting aside the admissibility of this testimony…
giuffre-maxwell
1320-20
11 pg
…counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
Case 1:15-cv-07433-LAP Document 1320-20 Filed 01/03/24 Page 7 of 11
Putting aside the admissibility of this testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.189.0
11 pg
…and counsel for the witness with a 3 hour
deposition to accomplish the same end.
5
Case 1:15-cv-07433-LAP Document 189 Filed 06/06/16 Page 7 of 11
Putting aside the admissibility of this testimony…
giuffre-maxwell
gov.uscourts.nysd.447706.634.0_2
15 pg
…no. I
18 just don't know. I don't know whether the testimony by this
19 witness is going to involve a statement by the defendant or
20 what it's going to involve. But it is conceivable, it…
DataSet-11
EFTA02725090
19 pg
…that she claims to have been interacting with Epstein, her evasive
responses to direct deposition questions, her admitted deceptions to her own
experts, her revelation that her testimony cannot be relied upon, even under oath,
her admissions regarding her positive…