EFTA00589467Set 9
2017-03-138p2,425w
most significant circumstance. It should
be examined, however, from the perspective of a non-party witness' loyalty to the
plaintiff or defendant, as the case may be. The closer ... bond, whether by reason 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 ... 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
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589467.pdf
EFTA01076133Set 9
2009-10-2625p7,430w
issuance of a protective order
concerning a deposition duces tecum of a non-party witness, pursuant to Rule
1.280(B)(1)(c), Fla. R. Civ. P., providing that, where good
https://www.justice.gov/epstein/files/DataSet%209/EFTA01076133.pdf
EFTA01660077Set 10
2010-03-1014p3,764w
UFDL") provides
a road map for litigants seeking to secure evidence from foreign non-party witnesses, stating
(2) Whenever any mandate, writ or commission is issued out of any court ... Dated: March 12, 2010
Respectfully submitted,
TAMA BETH KUDM AN, P.A.
Attorney for Non-Party Witness, Jean Luc Bruhnel
777 South Flagler Drive
Suite 800 - West Tower
-5-
EFTA01660081
Case
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01660077.pdf
EFTA00609377Set 9
2016-09-152p279w
Defendant.
x
WHEREAS on September 15, 2016, this Court ordered,
inter alia, that non-party witness be
directed to appear for deposition; and
WHEREAS on January 17, 2017, non-party
https://www.justice.gov/epstein/files/DataSet%209/EFTA00609377.pdf
EFTA00097394Set 9
2016-06-0612p3,169w
relevance to Plaintiff's request to take more than 10 depositions of non-party witnesses.
Conspicuously absent from Plaintiff's motion are (a) any actual information she believes
these witnesses ... cert denied, 459 U.S. 835 (1982) ("Furthermore, since King
was a non-party witness, no adverse inference against appellees could have been drawn from his refusal
to testify.").
3
EFTA00097398
https://www.justice.gov/epstein/files/DataSet%209/EFTA00097394.pdf