of blood, friendship or business, the less likely the non-party witness would be to render testimony in order to damage the relationship. 2. The Degree of Control of the Party Over the Non-Party Witness: The degree of control which the party has vested in the non-party witness in regard to the key facts and general subject mat

is Procedural Issue 2 B. The LiButti Factors Point in Favor of Allowing to Call Epstein. 2 1. The Nature of the Relevant Relationships 3 2. The Degree of Control of the Party Over the Non-Party Witness 7 3. The Compatibility of the Interests of the Party and the Non-party Witness in the Outcome of the litigation 9 4. The