Court filing discusses deposition tactics and alleged conspiracies in Giuffre case

10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25 143 H3vlgiu2 they're going to say if we don't have an opportunity to present them to the jury. The Court will recall the extraordinary lengths to which Ms. Giuffre had to go to procure their testimony. They finally were able to secure it, and they should be presented. Also -- I think you'll be hearing these issues next week we used some leading questions during the deposition. We tried to also use some nonleading. Leading questions can be used when? When you have a witness who's associated with the party on the other side. Well, we said they're ina conspiracy. I can't imagine a case where there would be a clearer example of when leading questions would be appropriate. The final argument they made, I think last night in their late replies was that we somehow missed the deadline in taking their deposition. What they don't disclose I think in their papers is, your Honor will recall that we had to come to you, obtain an application for alternative service, and then, as a result of that, they came in. We did all these things with the Court's blessing and approval of taking depositions. Those schedules were discussed with opposing counsel. And as soon as we'd taken the deposition, within approximately a week, we provided the designations. That was back in February of this year. There's no prejudice. So for all these reasons, we would ask that we be allowed to present two of the co-conspirators in the witness SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 HOUSE_OVERSIGHT_011446