Epstein Secrets

Deposition for Juan Alessi on May 31, 2016, without any conferral with counsel, in Florida, fully aware that defense counsel would be traveling from Colorado. Defense counsel, in fact, did have to travel on Memorial Day to Florida for the 9:00 a.m. May 31 deposition. Mr. Alessi, however, did not appear o

) 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

ectronic Filing generated by CM/ECF. Laura A. Menninger, Esq. Jeffrey Pagliuca, Esq. HADDON, MORGAN & FOREMAN, P.C. 150 East 10th Avenue Denver, Colorado 80203 Tel: Fax: Email: 21 /s/ Sigrid S. McCawley Sigrid S. McCawley EFTA00622198 United States District Court Southern District of New York

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

. McCAWLEY: Okay. 21 THE COURT: Does that work for you all? 22 MR. PAGLIUCA: I can't do the 10th, your Honor, I'm in 23 a deposition all day in Colorado. I'm sorry. 24 THE COURT: How could you possibly take another case? 25 MR. PAGLIUCA: Well, believe me, I have a lot of SOUTHERN DISTRICT REPORTE

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

he 10th. MS. McCAWLEY: Okay. THE COURT: Does that work for you all? MR. PAGLIUCA: I can't do the 10th, your Honor, I'm in a deposition all day in Colorado. I'm sorry. THE COURT: How could you possibly take another case? MR. PAGLIUCA: Well, believe me, I have a lot of SOUTHERN DISTRICT REPORTERS, P.C.

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

0th. MS. McCAWLEY: Okay. THI Gl COURT: Does that work for you all? MR. PAGLIUCA: I can't do the 10th, your Honor, I'm in a deposition all day in Colorado. I'm sorry. THE COURT: How could you possibly take another case? MR. PAGLIUCA: Well, believe me, I have a lot of SOUTHERN DISTRICT REPORTERS, P.C.

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