Epstein Secrets

F on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIE

TION TO EXTENDING DEADLINE TO COMPLETE DEPOSITIONS AND MOTION FOR SANCTIONS FOR VIOLATION OF RULE 45 via ECF on the following: Sigrid S. McCawley Paul G. Cassell Meridith Schultz 383 S. University Street BOIES, SCHILLER & FLEXNER, LLP Salt Lake City, UT 84112 401 East Las Olas Boulevard, Ste. 1200 cassel

) 19 Grochowski v. Phoenix Const., 318 F.3d 80, 86 (2d Cir.2003). 5 lantosca v. Benistar Admin. Svcs., Inc., 765 F.Supp.2d 79 (D. Mass. 2011) 6 LiButti v. United States, 107 F.3d 110, 121 (2d Cir. 1997) 16 Murphy v. Board of Educ., 196 F.R.D. 220, 222 (W.D.N.Y.2000) 19 Perfect Pearl Co., Inc. v

Edwards (Pro Hac Vice) FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law University of Utah 383 University St. Salt Lake Cit UT 84112 4 This daytime business address is provi

Suite 2 Fort Lauderdale, Florida 33301 Paul G. Cassell (Pro Hac Vice) S.J. Quinney College of Law Univ

Deposit Co. of Maryland, 45 F.3d 969 (5th Cir. 1995) 6 In re WorldCom, Inc. Securities Litigation, 2005 WL 375315 (S.D.N.Y. Feb. 17, 2005) 17 LiButti v. United States, 107 F.3d 110 (2d Cir. 1997) passim Rules Fed. R. Evid. 611(c) 16 ii EFTA00622177 Plaintiff respectfully submits her repl

this is a voice message that SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA_R1_00024127 EFTA01737531 21 G6ndgium Ms. Churcher left for Paul Cassell, who is a lawyer in this case who entered an appearance in this case, in February of 2015. 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 1

been provided, and it's germane to the issues before the Court. But what it reveals is that this is not Ms. Churcher's first interaction with Mr. Cassell, lawyer for the plaintiff. They are on a first-name basis. She is feeling free to call him and leave messages for him. And what she wants to discu

t would not justify a deposition, which leaves really the Fifth Amendment implications that have been represented will be made, and that raises the LiButti issue. And under LiButti, your Honor, really the permeating factor is control. And the typical case -- really, most of the cases, to the extent co

101 H3v1giu2 1 MR. CASSELL: All right. Well, we thought, when we 2 filed our response, they continued to oppose it. If they had 3 just stipulated, you know, I wouldn't be t

ing to conceal that from the jury or are we going to present 7 it to them? Well, the Second Circuit case that your Honor is 8 well familiar with, LiButti, sets out the factors that have 9 determined that issue, and one of the things we hear from the 10 defendant is, oh, it's never been applied in a

1 2 3 4 5 6 7 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 H3v1giu2 101 MR. CASSELL: All right. Well, we thought, when we filed our response, they continued to oppose it. If they had just stipulated, you know, I wouldn't be taking

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 101 H3vlgiu2 r MR. CASSELL: All right. Well, we thought, when we filed our response, they continued to oppose it. If they had just stipulated, you know, I wouldn't be taking y

we going to conceal that from the jury or are we going to present it to them? Well, the Second Circuit case that your Honor is well familiar with, LiButti, sets out the factors that have determined that issue, and one of the things we hear from the defendant is, oh, it's never been applied in a case l