DataSet-9
EFTA00802160
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
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.447706.1320.24
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.447706.824.0_2
47 pg
…case.
15 So, your Honor, I believe, in my view, that there is
16 definitely a plethora of witness testimony we can utilize to,
17 first, authenticate under 901, which, as you know, that burden
18 is not extremely high…
DataSet-9
EFTA00091739
10 pg
…strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims…
DataSet-9
EFTA00089364
10 pg
…strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims…
DataSet-9
EFTA00066307
10 pg
…strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims…
DataSet-9
EFTA00100628
10 pg
…strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims…
DataSet-10
EFTA01659412
10 pg
…strong.
Multiple victims have provided detailed, credible, and corroborated information against the
defendant. The victims are backed up contemporaneous documents, records, witness testimony,
and other evidence. For example, flight records, diary entries, business records, and other evidence
corroborate the victims…
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…