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Document 28509

AI Analysis

Summary: The document discusses the plaintiff's request to exceed the deposition limit in a defamation case, arguing that certain individuals' testimony is irrelevant or cumulative. The defendant, Ms. Maxwell, opposes the request, citing the simplicity of the defamation case and the lack of information provided by the plaintiff about the expected testimony of certain individuals.
Significance: This document is potentially important because it reveals the defendant's argument against exceeding the presumptive deposition limit and highlights the relevance of certain testimony in a defamation case.
Key Topics: deposition limits relevance of testimony defamation case
Key People:
  • Plaintiff (Jane Doe No. #3) - the plaintiff in the defamation case
  • Ms. Maxwell - the defendant in the defamation case
  • Jeffrey Epstein - individual associated with the plaintiff and defendant
  • Nadia Marcinkova - potential deponent
  • Sarah Kellen - potential deponent
  • Rinaldo Rizzo - potential deponent
  • Jean Luc Brunel - potential deponent
Document Type
Court Filing
Date
07/06/21
Pages
1
Folder
IMAGES002

Full Text

Case 1:19-cv-03339-RWS Document 28509 Filed 07/06/21 Page 6 of 112 Putting aside the admissibility of this testimony, it appears that both men were involved in the investigation of Mr. Epstein and are expected to testify about their investigation. Plaintiff's allegations were not a part of their investigation, which took place years after Plaintiff left the country. Moreover, their investigation did not involve Ms. Maxwell. Again, such duplicative and irrelevant deposition testimony speaks to the intended purpose of the ten-deposition limit, not a reason to exceed that limit. The same holds true for Nadia Marcinkova, Sarah Kellen (a/k/a Sarah Kensigton or Sarah Vickers) and Jeffrey Epstein, each of whom Plaintiff anticipates will not respond to questions and invoke their Fifth Amendment right. As discussed above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative. Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected testimony. Thus, it is unclear how these individuals have information that differs from or would add to the other proposed deponents. It is the Plaintiff's burden to explain to the Court why these depositions should be permitted if they exceed the presumptive limit, why the information would not be cumulative, and its relevance to the important issues in the action, or the importance of the discovery in resolving those issues. She simply fails to provide any information by which the Court can assess these factors, and thus should not be permitted to exceed the deposition limit based on her proffer. III. THE TESTIMONY SOUGHT IS IRRELEVANT TO THIS SINGLE COUNT DEFAMATION CASE This case is a simple defamation case. Plaintiff, through her counsel, filed a pleading making certain claims regarding "Jane Doe No. #3" - the Plaintiff - and her alleged