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…
DataSet-9
EFTA01130775
6 pg
…party, witness, or person providing
discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and…
DataSet-9
EFTA00095520
7 pg
…party, witness, or person providing
discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and…
DataSet-9
EFTA00074958
6 pg
…party, witness, or person providing
discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and…
giuffre-maxwell
gov.uscourts.nysd.447706.39.1
7 pg
…party, witness, or person providing
discovery in this case, IT IS ORDERED:
1. This Protective Order shall apply to all documents, materials, and information,
including without limitation, documents produced, answers to interrogatories,
responses to requests for admission, deposition testimony, and…
DataSet-9
EFTA00729278
7 pg
…deposition testimony as a witness in the instant matter or other Jane Doe
matters where she has been identified as a witness.
It is well settled that a Defendant may take the deposition of a party and/or a witness…
DataSet-9
EFTA00729285
7 pg
…deposition testimony as a witness in the instant matter or other Jane Doe
matters where she has been identified as a witness.
It is well settled that a Defendant may take the deposition of a party and/or a witness…
DataSet-9
EFTA01082212
7 pg
…there would be certain conditions, including the presence of Your Honor.
We submit that Mr. Dubin is not a mere third-party witness here, whose deposition
testimony would serve as his trial testimony. Surely Mr. Dubin knew the affidavit was…
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
EFTA00076468
20 pg
…on the part of [the witness] to cooperate with the
government" is proper subject of Rule 17(c) subpoena). Similarly, documents containing prior
statements of a witness that are inconsistent with that witness's testimony at trial can be
admissible…
DataSet-9
EFTA00804162
79 pg
…a roll there.
13 But in any event, your question --
14 object to the form. It mistakes your prior
15 question and the witness's prior testimony.
16 THE WITNESS: Sorry. Could you ask it
17 again?
18 BY MR…
DataSet-9
EFTA00794238
8 pg
…and that he had never seen the disc (Ex. B, ¶ 6). Epstein
confirmed this testimony during his deposition. (Ex. A, 25:24-26:8.) He testified that he never
received a copy of the disc:
Q. Did you ever receive…
DataSet-9
EFTA00794246
8 pg
… 6). Epstein
confirmed this testimony during his deposition:
Q. How is it that you can tell us under oath today that you had
no prior knowledge of Fowler White having come into
possession of a disc relating to your litigation…
DataSet-9
EFTA00795577
5 pg
…2017
Page 2 of 5
potential areas for inquiry. My testimony will be as an objective witness providing what I
believe constitutes truthful and accurate information and opinions, and any written report or
opinion letter that I provide will be…
DataSet-9
EFTA00795695
4 pg
…Likewise, any testimony that I might give
as a testifying expert will be as an objective witness sworn to provide what in my view
constitutes truthful and accurate information and opinions, and any written report or opinion
letter that I…
DataSet-9
EFTA00795691
4 pg
…Likewise, any testimony that I might give
as a testifying expert will be as an objective witness sworn to provide what in my view
constitutes truthful and accurate information and opinions, and any written report or opinion
letter that I…
DataSet-9
EFTA01099325
44 pg
…23, 2010 deposition You testified under oath (at
page 12), there are only three cases in existence against Jeffrey Epstein in which You
represent a plaintiff (Jane Doe, L.M. and..).
2. Admit that the testimony described in Request No…
giuffre-maxwell
gov.uscourts.nysd.447706.1335.7
469 pg
…and communicating that
20 information to the witness, which
21 you know is totally improper.
22 MS. MCCAWLEY: Now, that's
23 two people objecting right now.
24 Is it going to be Laura taking
25 this deposition or you…
DataSet-9
EFTA01120387
2 pg
…expert witnesses reasonably expected to be called by the Claimant
on or before July 23, 2012 .
a) The disclosure of witnesses shall include the full name of each witness, a
short summary of anticipated testimony, copies of any experts' reports…