…allow us to depose him because you said it was irrelevant. So we're now in a position where at trial they want to put forth that information against my client, and I don't have an under-oath statement from that individual saying whether or not he actually was. Now, what we k...
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10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 H3VOGIU1 (Case called) THI 1s COURT: Like all of you, you woke up in the middle of the night thinking about this case. I would like to see if I can clarify my understanding. In the motion to dismiss, I co...
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 62 H3VOGIU1 reputation at issue, all of these specific instances going to your honesty are fair game. In this case, we have asked plaintiff whether she filed tax returns. She said, "No." Tax fraud is not a pr...
… compliance issues coming in with regard to Ms. Giuffre. They've said, well, that goes to her credibility. What's good for Ms. Giuffre should be good for the defendant. But again, to be clear, we don't want to turn this into a tax trial; we want it to be a defamation trial. Bu...
…u2 and second of all -- so that's a rule of completeness, and second of all, you were there and you heard it and therefore, it would go to your state of mind and not for the truth of the matter asserted. The next case is United States v. Dupree. That's another criminal case...
…in our case? MS. MENNINGER: Your Honor, I think the jury would be instructed here not to hold Ms. Maxwell responsible for any harm to plaintiff's reputation caused by third parties or alternate sources, including stories that were generated by statements made by her own counsel...
… may or may not be admissible depending on what she says on the stand, but they are her statements and they are, therefore, potentially admissible as admissions of a party opponent under 801(d) (2). Moreover, her doctor is the one who wants to testify about her need for medic...
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 1138 H3vlgiu2 we're not offering any of this for the truth of the matter asserted. So 87 pages of police reports, a hundred pages or however many there are of trash, you know, witness transcripts, no, no, no,...
…putation is damaged by some other litigation that has nothing to do with Ms. Maxwell, Ms. Maxwell can't be responsible for that reputational damage. THE COURT: What's your explanation of the damage caused to Giuffre by the Dershowitz case? MS. MENNINGER: I'm sorry? 7 THE CO...
10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 99 H3vlgiu2 on the liability case. That's your position. MR. PAGLIUCA: That is my position, your Honor. THE. COURT: I think that's correct. Tell me why that's wrong. r MR. CASSELL: All right. Thank you, yo...
Case 1:15-cv-07433 Document1 Filed 09/21/15 Page 2 of 12 Plaintiff, VIRGINIA L. GIUFFRE, formerly known as Virginia Roberts (“Giuffre”), for her Complaint against Defendant, GHISLAINE MAXWELL (“Maxwell”), avers upon personal knowledge as to her own acts and status and otherwise...
…estopped from reraising them. And it would be seriously misleading, your Honor, to admit the joinder motion and not inform the jury that a judge found that the allegations contained in that joinder motion were impertinent. Motion in limine 20, Rebecca Boylan. They said she's...
…ything. I just got handed this stuff by plai the course of this deposition, and about it. So that's another piece for the plaintiffs. There a witness, Ms. to introduce that transcript or, an audio recording of an in which they are ntiff that "s counsel, you know, in...
…I Gl COURT: case that counsel has given me The motion was Your Honor, All right. it should in limine to Assume for is accurate, —- well, even assuming, 97 Because it was denied, your Honor. okay. arguendo, still be admitted exclude it as the moment that the and...
…ncident happened in early March, 2015, a couple of months after the allegedly defamatory statement, and seven months before plaintiff brought this lawsuit. The criminal proceedings against her husband also are relevant to her damages, apart from Dr. Kliman's testimony. Her husb...